Published in 'The Ecologist', 8th July 2014, under the title, "An abuse of science – concealing fracking's radioactive footprint"
As the facts about unconventional gas emerge around the globe the UK Government and the on-shore oil and gas industry have been pulling-down the shutters on their grand project. Increasingly reports are "being seen to be written rather than written to be seen". For example, last week Public Health England launched the final version of their report on shale gas and health – on the same day that the Jimmy Saville inquiry results were reported. That pretty much ensured there would be no room in the schedules for any critical analysis of it.
As Government and industry have retreated into their ideological comfort zone, avoiding public debate on these issues, their defence of unconventional oil and gas policy has become increasingly tenuous. In the face of the evidence now available, they are acting in blind ignorance of the facts we can established from other nations where unconventional oil and gas are being exploited on a large scale. In my view, that indifference to the evidence is such that it could be considered criminally negligent.
The most recent addition to the Government's Pantheon of misinformation emerged last week. With little fanfare, Durham University issued a press release to publicise a new research paper from the 'ReFINE' project (a.k.a. Researching Fracking IN Europe, a joint academic, Government and industry project to research the impacts of unconventional oil and gas). Its title; "Research finds fracking would increase water radioactivity but would not pose a threat to public health".
I was immediately suspicious since recent research has found the opposite, so I downloaded the paper. They were in such a hurry to get it into the public domain they hadn't even waited for the journal, who had just accepted it, to typeset it for publication. The PDF file was the raw copy which the journal's peer reviewers had just approved.
And what did the paper say? Nothing. Or rather, nothing which could be readily verified as accurate.
Let's begin with their concluding remarks –
This study shows that shale gas exploitation will result in increased flux of radioactive elements to controlled waters including to surface water bodies. However, it is clear that fluxes are within range of those that might be experienced elsewhere in the world from use of natural groundwaters; lower than other discharges even from the non-nuclear sector; and lower than those from other energy production including both conventional offshore oil and gas production.
Now what do they mean by "natural groundwaters"?
They don't mean the local groundwater springs of Lancashire. They're quoting levels of radioactivity found in a very few 'radioactive springs'. For example: the spas of Andalusia in Spain; or the historic hot springs on the Greek island of Ikaria, where workers in the spas can receive radiation exposures which wouldn't be allowed in the nuclear industry.
Such "naturally" toxic environments are rare; and highly radioactive springs are also the rare exception, not the rule. They occur in a few locations, mostly in geological subduction zones – such as in the Southern Mediterranean.
That's the problem with the word "natural". From naturally toxic soils, to volcanic caves with acidic atmospheres which dissolve your lungs, the world contains many "natural" wonders which are quite harmful to humans. There's even a geological strata in Gabon which is so rich in uranium that when, millions of years ago, groundwater flowed through the rock it underwent "natural" nuclear fission. A fact which the nuclear industry played upon during the 1980s to try and greenwash nuclear power as a "natural" technology.
The Durham paper uses these exceptions to justify the rule. In reality, most of the groundwater springs around the world produce perfectly drinkable water, low in radioactivity and harmful dissolved minerals. This fact, and the impact of the produced water from fracked wells, was alluded to in the Durham paper –
The total activity for Bowland flowback fluid is ~2.5 MBq/yr, this compared to ~0.021 MBq/yr in surface waters, a difference of 2 orders of magnitude [or 100 times greater]. This highlights a potentially large risk if surface waters were to become contaminated with flowback fluid.
We must also question the data they used as the basis of their calculations for the Bowland shale – and the method used to calculate radiation doses.
Their figures are based on just one site which the Environment Agency monitored – at Preese Hall in Lancashire. That's a questionable use of data since it assumes this one site is representative of the entire Bowland shale – and hence the whole of Britain. It is a highly unlikely scenario given the innate geological variability of shale, and given the potential impacts upon the environment and human health it is a highly irresponsible approach.
In any case the Environment Agency's sampling of the well was pretty poor. The monitoring data shows eight sample results spread over a period of three months – which qualitatively tells us little about the statistical distribution of pollutants produced by Bowland shale wells over their gas-producing lifetime.
To be statistically rigorous in characterising a 'Bowland shale radioactive fingerprint' we'd need a few thousand samples from a few hundred wells, with a wide geographical spread – and a similar exercise in every other gas producing area to characterise their footprints too. Therefore when this paper assumes a statistical distribution of pollution in order to carry out it's calculations, it's doing so on a highly tenuous set of assumptions about the nature of the Bowland shale.
It is from this poor statistical base they make a gigantic leap – to calculate the radiation exposure of the public from flowback water. And what did they deduce? –
In no scenario was the 1% exceedence exposure greater than 1mSv – the allowable annual exposure allowed for in the UK.
The exposure limit in the UK is not 1 milli-Sievert (mSv) per year. That's the whole body annual dose from ALL man-made sources. For regulatory purposes the maximum dose permitted from a SINGLE source is 0.5mSv per year. More importantly, any source which gives a dose greater than 0.02mSv per year (which gives greater than a 1 in a million chance of cancer) has to be investigated; and, if required by law, issued with a permit which will require certain actions to minimise its impacts upon health and the environment.
That's the big backroom debate in Whitehall and in the Environment Agency's HQ at the moment. And it's a debate which is arguably one sided given that their departing Chairman, Lord Smith, thinks that fracking is safe, even in national parks.
The Government wants to deregulate – but international agreements on radiological protection require the opposite. Given the level of radioactivity in the discharges, the Environment Agency must regulate every fracking pad as a single radioactive discharge. That creates a lot of form-filling and monitoring problems for the shale gas industry.
As a result, bit by bit, the Government are trying to dismantle our environmental laws in order to allow unconventional oil and gas to go ahead. Trouble is they can't be discriminatory. If they were to relax the law for on-shore oil and gas, then the nuclear industry could argue that they too should be released from these regulatory burdens.
Given the current regulatory restrictions, the Durham paper states a startling proposition –
For this calculation it was assumed that the volume of water being used by a person on a daily basis was from flowback fluid and then the radioactive flux to that person that would be the case from each of the scenarios considered.
Now, what is it that you do with water? Before writing this article I asked a few people what they did with water and the first thing they said was, "drink it".
That's not the case in the Durham paper.
The paper sets out a method for calculating radiation doses which doesn't properly evaluate the radiation dose to an affected group, nor the most exposed individual – which is the regulatory approach taken in Europe and much of the developed world. They should have considered both the external dose from daily water use, but also the more significant issue of water consumption. This produces a far greater impact upon health due to the action of 'internal emitters'.
From their method, it would appear that only the lesser 'external dose' has been considered, giving a false result for the impact of these discharges upon health. Nor does the paper state the source of one of the critical values (called 'k') which converts the level of radioactivity consumed into a whole body radiation dose. Therefore we can't independently verify the results presented in the paper.
Finally, they perform a statistical slight of hand which reduces the impacts upon dose even further – calculating the total flowback water production from a certain number of wells based upon their tenuously assumed distribution of pollutants. A randomly generated sample of these 'probabilistic' figures then forms the input to their dose calculations.
To calculate the impact of contaminated water ingestion is straightforward, using the standard assessment procedure set by the International Committee for Radiological Protection (ICRP):
The above calculations based upon the Environment Agency's Preese Hall flowback data are shown in the table below.
|Annual effective dose from consumption of Preese Hall flowback fluid|
|Average concentration, Bq/kg||34.3||0.5||1.7||0.5||14.9||4.8||12.3|
|Water consumption, kg/yr||730|
|Effective doseC, mSv/yr||7.0007||0.0383||0.0077||0.0022||0.0015||0.0015||0.0010|
|Total effective doseD, mSv/yr||7.05|
|A – this is the sample ID from the Environment Agency's Preese Hall study|
B – Ingestion dose coefficient for members of the public set in Council Directive 96/29/EURATOM for a person >17 years of age
C – this figure is equivalent to radionuclide concentration × water consumption × CED for each radionuclide × 1000 (to convert to mSv)
D – this figure is the sum of the effective doses for each radionuclide
Doing that calculation for the Preese Hall flowback water, the result isn't anywhere near the 0.02mSv per year stated in the paper. It's over 7mSv per year, most of which is due to the high levels of radium-226. The difference between these figures is not unexpected. This issue of contention is that the calculations behind the Durham figure neglect the impacts of ingesting radiation.
As a result the public can't independently know that these results are accurate; but perhaps that's the point? Looking with a sceptical eye, what I see in this paper is an attempt to nullify the debate over the radiological footprint of shale gas.
We know from recent US research that, on river beds downstream of the discharge from flowback water treatment plants, "the level of radioactivity found in sediments at one brine-treatment discharge site exceeded the management regulations in the U.S. for a licensed radioactive waste disposal facility".
Another recent research paper, which examined the pit lagoons associated with well drilling and flowback, found that, "total beta radiation... found in this study exceeded regulatory guideline values by more than 800 percent".
Given what we know of the impacts of the industry elsewhere, the assumptions in this paper do not correlate to the reality of how unconventional oil and gas is likely to be extracted in Britain. Nor does it properly assess the radiological impact in accordance with the process which would be applied by the Environment Agency as part permitting. Nor by the Drinking Water Inspectorate if flowback water should ever end up in public water supplies. That this paper passed the peer review process should also raise concerns about the level of scrutiny to which such studies are subjected to.
The results of this paper present an idealised view which doesn't inform the public debate over unconventional oil and gas. Instead it misdirects the public's attention, away from the quite serious impacts which have been demonstrated in other research, and seeks to down-play the radiological impacts of fracking's discharges to the environment and human health.