26th June 2014: Misdirecting from fracking's radioactive footprint » 2014 » Mobbsey's Musings » Paul Mobbs/MEI » FRAW

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Misdirecting the public's attention from fracking's radioactive footprint

Paul Mobbs, Mobbs' Environmental Investigations, 26th June 2014
(updated 30th June 2014 with additional data/calculations)


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[1] 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[2] 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[3].

The most recent addition to the Government's Pantheon of misinformation emerged last week. With little fanfare, Durham University issued a press release[4] to publicise a new research paper from the 'ReFINE' project[5] (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[6], 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[7] 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[8]; or the historic hot springs on the Greek island of Ikaria, where workers in the spas can receive radiation exposures[9] 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[10]. 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[11] 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[12], thinks that fracking is safe, even in national parks[13].

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[14] 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'[15].

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'[16] 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[17] (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
 Radionuclide, Bq/kg:
Sample IDA226Ra223Ra40K212Pb214Pb228Ac214Bi
L300480114000.41.41.70.9
L3005184162.13.50.962.65.1
L30057961703.30.72.32.92.1
L300954290000501241
Average concentration, Bq/kg34.30.51.70.514.94.812.3
Water consumption, kg/yr730
CEDB, Sv/Bq2.8E-71.0E-76.2E-96.0E-91.4E-104.3E-101.1E-10
Effective doseC, mSv/yr7.00070.03830.00770.00220.00150.00150.0010
Total effective doseD, mSv/yr7.05
A – this is the sample ID from the Environment Agency's Preese Hall study
BIngestion 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[19]. 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[20] 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[21], 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[22] as part permitting. Nor by the Drinking Water Inspectorate[23] 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.


References:

  1. Review of potential public health impacts from shale gas extraction, Public Health England, 26th June 2014 – https://www.gov.uk/government/news/review-of-potential-public-health-impacts-from-shale-gas-extraction
  2. Fracking – you are not important, Paul Mobbs, The Ecologist, 24th June 2014 – http://www.theecologist.org/blogs_and_comments/commentators/2450429/fracking_you_are_not_important.html
  3. Misconduct in Public Office, Prosecution Policy and Guidance, Crown Prosecution Service, June 2012 – http://www.cps.gov.uk/legal/l_to_o/misconduct_in_public_office/
  4. Research finds fracking would increase water radioactivity but would not pose a threat to public health (press release), Durham University, 24th June 2014 – https://www.dur.ac.uk/news/newsitem/?itemno=21542
  5. ReFINE Project, Durham University – https://www.dur.ac.uk/refine/
  6. Radionuclides in Fracking Wastewater: Managing a Toxic Blend, Valerie J. Brown, Environmental Health Perspectives, vol.122 no.2 pp.A50-A55, February 2014 – http://www.fraw.org.uk/files/extreme/brown_2014.pdf
  7. The flux of radionuclides in flowback fluid from shale gas exploitation, S. Almond, S.A. Clancy, R.J. Davies, F. Worrall, Environmental Science and Pollution Research, 24th June 2014 – http://www.fraw.org.uk/files/extreme/almond_2014.pdf
  8. Natural Radioactivity Levels in Andalusian Spas, C. Duenas et al., Water Research, vol.32 no.8 pp.2271-2278, 1998 – http://atarazanas.sci.uma.es/docs/articulos/16724045.pdf
  9. Estimation Of Dose Rates To Humans Exposed To Elevated Natural Radioactivity Through Different Pathways In The Island Of Ikaria, Greece, G. Trabidou and H. Florou, Journal of Radiation Protection Dosimetry, December 2010 – http://rpd.oxfordjournals.org/content/early/2010/10/13/rpd.ncq269.abstract
  10. Wikipedia: 'Natural nuclear fission reactor'http://en.wikipedia.org/wiki/Natural_nuclear_fission_reactor
  11. Shale Gas: North West – Monitoring of Flowback water, North West Region, Environment Agency, 6th December 2011 – http://www.fraw.org.uk/files/extreme/envage_flowback_2011.pdf
  12. Fracking safe? In national parks? What is Lord Smith smoking?, Dr David Lowry, The Ecologist, 28th June 2014 – http://www.theecologist.org/blogs_and_comments/commentators/2456579/fracking_safe_in_national_parks_what_is_lord_smith_smoking.html
  13. Allow fracking in national parks, says Environment Agency chief, Ben Quinn, The Guardian, Saturday 28th June 2014 – http://www.theguardian.com/environment/2014/jun/28/allow-fracking-national-parks-environment-agency
  14. Regulatory Roadmap: Onshore oil and gas exploration in the UK regulation and best practice, Department of Energy and Climate Change, 17th December 2013 – https://www.gov.uk/government/publications/regulatory-roadmap-onshore-oil-and-gas-exploration-in-the-uk-regulation-and-best-practice
  15. Report of the Committee Examining Radiation Risks of Internal Emitters, CERRIE, October 2004 – http://www.fraw.org.uk/files/nuclear/cerrie_2004.pdf
  16. Wikipedia: 'Probability interpretations'http://en.wikipedia.org/wiki/Probability_interpretations
  17. Wikipedia: 'International Commission on Radiological Protection'http://en.wikipedia.org/wiki/International_Commission_on_Radiological_Protection
  18. Council Directive 96/29/EURATOM, laying down basic safety standards for the protection of the health of workers and the general public against the dangers arising from ionizing radiation, Official Journal of the European Communities, no. L.159, Volume 39, 29th June 1996 – http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:1996:159:FULL&from=EN
  19. Wikipedia: 'Radium, Radioactivity'http://en.wikipedia.org/wiki/Radium#Radioactivity
  20. A Critical Review of the Risks to Water Resources from Unconventional Shale Gas Development and Hydraulic Fracturing in the United States, Avner Vengosh, Robert B. Jackson, Nathaniel Warner, Thomas H. Darrah, Andrew Kondash, Environmental Science and Technology (preprint), 7th March 2014 – http://www.fraw.org.uk/files/extreme/vengosh_2014.pdf
  21. Analysis of Reserve Pit Sludge From Unconventional Natural Gas Hydraulic Fracturing and Drilling Operations for the Presence of Technologically Enhanced Naturally Occurring Radioactive Material (TENORM), Alisa L. Rich, Ernest C. Crosby, New Solutions, vol.23 no.1 pp.117-135, March 2013 – http://www.fraw.org.uk/files/extreme/rich_2013.pdf
  22. Principles for the Assessment of Prospective Public Doses arising from Authorised Discharges of Radioactive Waste to the Environment, Environment Agency, August 2012 – https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/296390/geho1202bklh-e-e.pdf
  23. Section 12/Annex 2, Guidance on the Water Supply (Water Quality) Regulations 2000 (England), Drinking Water Inspectorate, 6th September 2010 – http://dwi.defra.gov.uk/stakeholders/guidance-and-codes-of-practice/WS(WQ)-regs-england2010.pdf