Regulation

The acid debate – what the Environment Agency says about acidising oil and gas wells and how campaigners respond

171223 Broadford Bridge drone 1 BBAG

UKOG’s Broadford Bridge site in West Sussex. Photo: Broadford Bridge Action Group

The use of acid in oil and gas wells is dividing opinion across the country, particularly in southern England and parts of the East Midlands.

Operating companies have argued it is a routine technique designed to clean wellbores. Campaigners have argued that it could be fracking under the radar with similar risks.

The Environment Agency recently published a set of frequently asked questions and answers (FAQs) about the use of hydrochloric and hydrofluoric acids at oil and gas exploration and production sites.

The FAQs give details of how the Environment Agency will interpret techniques including acid wash, matrix acidisation, acid squeeze and fracture acidising.

DrillOrDrop asked groups researching and campaigning about acidisation in southern England to review the FAQs. This post looks at the key points and the groups’ responses.

Some of the comments are from the Weald Action Group, which has produced its own leaflet (link to pdf here). The group described the Environment Agency’s FAQs as “a start in the right direction” but “too vague to give confidence that this operation can be properly regulated”.

Environment Agency use of acid at oil and gas sites

Extract from the Environment Agency’s FAQs

Techniques

The Environment Agency’s FAQs describe a range of techniques using acids.

Acid wash The Environment Agency defines this as a technique to clean the well following drilling or after use. It is not considered to be a well stimulation method. The FAQs suggest acid wash usually uses hydrochloric acid (HCl) at a concentration of about 7%.

Matrix acidisation According to the FAQs, this technique involves injecting or squeezing dilute acid into the geological formation at a pressure below that needed to fracture rocks. The acid enlarges natural pores, fractures and fissures, increasing the productivity of the well. The Enviornment Agency said it considers this to be a form of stimulation.

Acid fracturing or fracture acidisation This is defined in the FAQs as pumping dilute acid into the formation at pressures that will fracture as well as dissolve rocks. This is also regarded as a form of stimulation.

Acid squeeze The FAQs say this technique dissolves rock and may open new fractures. It is used for areas close to the well to make it more productive.

Weald Action Group said:

“We are pleased to see some distinction between routine maintenance and stimulation.

“Setting the bar at 7% hydrochloric acid for acid wash is again a good start but how will this be regulated?

“The Environment Agency assumes industry usually uses 7% and that acid wash is not considered a stimulation of the formation. Yet at Markwells Wood, a UKOG site in West Sussex, the company consistently claimed it was going to wash with 15% hydrochloric acid.

“How will the Environment Agency be able to distinguish between a matrix acidisation and an acid frack?

“Matrix acidisation and acid fracking carry similar risks as hydraulic fracturing but there are even more unknowns with acidisation because of the lack of historical permitting and monitoring. “Acidisation also uses a higher percentage of chemicals than hydraulic fracturing and there may be a greater cumulative impact because a well can be repeatedly acidized within its lifetime.”

Chemicals

The FAQs say hydrochloric acid is used to dissolve carbonate rocks, such as limestone (calcium carbonate) and dolomite (calcium magnesium carbonate), or calcite cement.

Hydrofluoric acid is less commonly used and is required to dissolve quartz or silica in rocks, such as sandstone or clay.

The FAQs say other chemicals may be added to protect the integrity of the well and refer to:

  • Inhibitors to prevent acid damaging the steel casing
  • Sequestering agents to prevent the formation or gels or precipitation of naturally-occurring iron compounds.

Weald Action Group responded:

“Acidising tight reserves is complex and typically many kinds of chemicals are used along with the acid, not just two”.

The group asked:

“What about cationic surfactants to inhibit sludge, mutual solvents, friction reducers, acid fluid loss additives, diverting agents, clay stabiliser, calcium sulphate inhibitors, scale inhibitor, ph adjusting agent, clean-up additives and biocides?

“In recent applications at Broadford Bridge, Lidsey and Wressle, there was a list of about 20 chemicals, many of them extremely toxic.”

wressle-site-plan-application-to-nlc

Plan for the Egdon’s Wressle site in north Lincolnshire where the use of hydrofluoric acid was proposed. Source: Egdon Resources

Waste

The FAQs explain that hydrochloric acid reacts with calcium carbonate rock to form calcium chloride salt and water plus carbon dioxide gas. Acid that has reacted with rocks is referred to as “spent acid”. The FAQs say:

“It is expected that the amount of acid used will be calculated to balance with the amount of rock that needs to be treated, so that the acid will have been used up in the chemical reaction. If the fluid coming to the surface is still acidic, it is neutralised with soda ash.

“We require details of the treatment to be included in a waste management plan, which is submitted with the environmental permit application documents.”

Weald Action Group said the description of waste products was “inadequate”:

“There is no consideration of the unpredictable nature of by-products. We’d like to see a requirement for on-site testing of waste water and for logging and monitoring of this.”

“We need to demand that the companies are bonded or pay financial guarantees for transport of waste water considered hazardous, just as with fracking.”

Balcombe,West Sussex, UK Anti Fracking protests..16th September

Tanker leaving Cuadrilla’s oil exploration site at Balcombe in September 2013. Photo: David Burr

No Fracking in Balcombe, which campaigned against Cuadrilla’s oil exploration site in the village, said:

“Companies, for example Cuadrilla in Balcombe, call their waste water euphemistically ‘salty water’, yet it is likely to contain heavy metals brought up from underground, radioactive materials, and quantities of salt up to five times the typical level in sea water.

“It is likely to be difficult and expensive to treat, and once treated it is likely to be dumped on land or (diluted until the contaminants fall below legal limits) into the sea. Returning acidising fluids are by no means always neutralised. Workers have to take great care, especially when using the very highly corrosive hydrofluoric acid. American unions are campaigning to have hydrofluoric acid banned on oil and gas sites.”

Risk

The FAQs say the Environment Agency would not permit a proposed activity if it posed an unacceptable risk to the environment.

“We will only issue an environmental permit if we are satisfied the proposed activities meet the requirements of all the relevant legislation”.

Weald Action Group responded:

“What is the relevant legislation around acidisation?

“There are still so many unknowns about acidisation. We are not being adequately protected. Loopholes still exist that make life very easy for industry.”

The FAQs say that as part of its assessment of risk, the Environment Agency looks at the acid and other chemicals, the proposed activity, the geology, the well and the treatment of waste. It applies a standard Source-Pathway-Receptor conceptual model to assess risk, considering how the acid could reach the groundwater.

Weald Action Group said:

“There are no peer reviewed studies available regarding the dissolution and mobilization of naturally-occurring heavy metals and other pollutants from the oil-bearing formation, specifically with regard to acidisation.

“There is no analysis of the chemicals being injected and the fate and effect of well stimulation fluids in the subsurface.

“How then can the EA make proper assessments using the Source-Pathway-Receptor model?”

Brockham well Brockham Protection Site

Angus Energy’s Brockham site, winter 2016-2017. Photo: Brockham Oil Watch

Brockham Oil Watch, which has been following Angus Energy’s operation at Brockham in Surrey, pointed to stricter regulation in the US. The environmental conservation committee of Florida’s senate unanimously approved a bill recently to ban fracking of all kinds, including acid fracking and matrix acidising. In 2013, California’s state legislators required permits for all well stimulation treatments, including the use of acid. The regulations also require the notification of neighbours, public disclosure of all chemicals and groundwater and air quality monitoring.

Conventional or unconventional?

The Environment Agency says the FAQs apply only to the use of acidisation at what it calls conventional oil and gas exploration and production sites.

No Fracking in Balcombe said:

“This document discusses forms of stimulation, including acid fracking, which would clearly be used in unconventional situations. The Environment Agency is either naïve or keen to maintain the political fiction that limestone and sandstone are always conventional sources of hydrocarbons.

“Who do they think they are fooling? The use of acid is proposed at a number of sites in southern England that are described as conventional by operators when speaking to the general public, but unconventional when they address current and prospective shareholders.”

Weald Action Group said until target formations in the Weald and areas such as north Lincolnshire were defined as unconventional, regulation would be “inherently flawed”.

HORSE HILL FRACKING

Initial flow testing at Horse Hill in Surrey. Photo: Eddie Mitchell

Brockham Oil Watch has questioned Angus Energy’s description of its operations at Brockham as conventional:

“We have asked the Environment Agency to clarify how they define conventional versus unconventional sites, where Brockham would fall, and how the approach is different for unconventional sites.

“Based on the proposed completion programme of work for BRX4Z that Angus presented to, and received approval for from the Oil and Gas Authority, the proposed perforation interval is a c190 m zone that includes multiple layers of micrite and shale.

“Where shale rock is the source of hydrocarbons, the Planning Practice Guidance on mineral extraction defines them as unconventional.

“This matters because unconventional reservoirs will likely require stimulation to enable commercially viable flow.”

De minimis: what is it and why does it matter?

Environment Agency use of acid at oil and gas sites2.jpg

Extract from the Environment Agency FAQ

The FAQs say a permit for groundwater activity is not needed if the volume of substance used is too small to risk deterioration of the groundwater. It calls this activity de minimis.

The FAQs say an operation would be considered de minimis if:

  • The volumes of acid in an acid wash were very small
  • The acid would come into contact with a very small area of rock in the target formation
  • The acid would react to form an inert salt solution, water and carbon dioxide
  • The activity was not intended to inject acid a significant distance into the formation
  • There would be no significant residual acid fluid remaining in the target formation

The FAQs give as an example:

“The groundwater may contain naturally high concentrations of hydrocarbons and salts, making any impact from the discharge on the groundwater insignificant or trivial. The fluid is introduced under a controlled pressure so as not to create new fractures in the rock and so that it only penetrates the minimum required distance into the formation.”

Brockham Oil Watch said:

“We are concerned that much of the document is focused on the issue of how to define and deal with a de minimis activity, for which, in effect, regulation is not required.

The FAQs make no attempt to quantify what a de minimis activity is and so it is open to interpretation and potential avoidance of regulation by the oil companies.

“We have also asked the Environment Agency what volume of acid per unit of formation (based on its specific geological characteristics) will be the threshold between acid wash and acid stimulation for the two wells that Angus Energy say they will acid wash: BR-X2Y and BR-X4.”

Weald Action Group asks:

“We’d like to have further information on how the Environment Agency reaches the conclusion that a procedure is ‘environmentally trivial’. Will the 7% HCl be regulated?”

The group said some companies were claiming that their operations fell under routine well maintenance and were therefore de minimis when, in fact, they may be intending to stimulate the formation.

“Will the EA enforce these rules? And if the industry is non-compliant how long will this take to enforce?’’

Overview

No Fracking in Balcombe said:

“The Environment Agency’s grasp of acidisation is weak and waffly.

“The Environment Agency has learnt about acidisation and developed its stance on the hoof over the last couple of years, much, we would contend, in response to opinion, queries and FOIs from the public.

“On the positive side, it’s good to see the Environment Agency admit that an acid wash typically uses no more than a 7% acid solution, and that matrix acidising and an acid frack are forms of stimulation. It is good that the Environment Agency is beginning to see acidising as a process worthy of its attention.

“But this document selects its vocabulary with care, emphasising ‘cleaning out the well’, comparing acidising an oil or gas well to descaling a domestic kettle, comparing it spuriously to the use of acidisation in the water industry. ‘Only a small volume of dilute acid is required’. The Environment Agency’s vocabulary is de minimis.

“The Environment Agency writes of its commitment to protecting public and environment, and of its regulatory powers and potential sanctions. Guardian angels? After six years dealing with the Environment Agency, we see them as fallen, toothless angels, locked in a government and industry embrace, dwindling in number, and reduced to ticking boxes.”

Weald Action Group concluded:

“It is clear that this is a nascent regulatory regime based on very little knowledge about the impacts of acidisation on our environment and human health.

“We would like to see a moratorium on the practice until there is sufficient research on all aspects of acidisation.

“We deserve strong, meaningful, protective legislation that puts the health of our communities and environment first.”

“The concern is that in UK regulation the use of acid still falls under the wrong category of conventional production. We know that the target geology in the Weald is complex and oil does not flow naturally. We know that it is low permeability and large quantities of chemicals and/or acid fracking is are needed to release the oil. Acid maintenance procedures are passed off as routine and standard and bypass important regulatory scrutiny.

“Data gaps exist in all aspects of acidisation, including acid washing. There are significant uncertainties about the kinds of adverse health outcomes that may be associated with chemicals used in acidising and the effectiveness of some of the mitigation measures in reducing or preventing environmental impacts which could adversely affect public health.

“There is no evidence that this process can be conducted without risk to the environment and human health. We would expect the Environment Agency to have revised guidance and very distinct regulation for all aspects of acidisation. What is the guidance on acidising in unconventional formations?”

Links

Environment Agency FAQ

Weald Action Group leaflet

50 replies »

  1. Would you drink the water that is present in the target strata prior to oil or gas exploration Phil. And would anyone care to do that on camera amongst independent observers and chemical monitoring?

    Hydrofluoric acid is used regularly in the UK, it is used in large quantities and strength for the cleaning and preparation of boiler feed water and steam generation equipment, its use in the oil industry in comparison is very minor both in quantity and strength.

    There are companies in the UK that specialise in its manufacture, transportation and use. Why would its constituents be vague both in precise chemical compound and origin, is it not controlled or regulated the same as any other chemical manufactured in the UK?

    • Hi John,
      Interesting question, probably not, high saline i understand, but we are being asked to accept that the entire process of acid fracking is of no danger whatsoever, and i must admit that being told by one poster that, we know nothing and therefore cannot comment about it, did cause me to do what often happens when such patronising superior attitude presents itself? I tend to go for the jugular, or rather the acid frackular in this case?

      I admit to being somewhat doubtful about the claims of knowing nothing and that acid fracking is perfectly safe, my reaction does, i admit tend to be perhaps a little “caustic”? Like acid fracking, i suppose it does the job, but the residue can be toxic, great simile don’t you think? if we know nothing, then it is an excellent opportunity to educate is it not? Rather than insulting everyone with such a superior overbearing attitude.

      So i ask questions.

      I find people tend to actually start being reasonable with the facts when challenged on an equal basis, it should not be necessary but it does work, often the result is silence because it addresses aspects that would rather not be addressed by those who don’t want to address them..

      So congratulations in sticking with it, so i can begin to be reasonable myself.

      I still have doubts about the residues and gasses produced by acid reactions to rock strata and the attendant chemical additives, material intrusions and constituents that such activities inevitably produce as a by product and as part of the procedure.

      I am aware, by contacts with water companies, that the chemical additives called fluorides that are added to drinking water, do indeed come from many places including china and the containers have no specific labelling other than it is a fluoride compound, and like i said, of which there are thousands from all sorts of sources, combinations, compounds and constitunts.

      I am also aware that there is no earthly reason to put fluoride in drinking water other than its soporific and emotional and cognitive suppressant qualities, also fluorides are an industrial waste product and hence the water companies buy the stuff that would otherwise have to be expensively disposed of, or perhaps dumped somewhere.

      Please look that up if you are in any doubt about the truth of any of that.

      There are, i am sure you will admit, all sorts of questions that arise from such claims of all perfectly safe, since, as you say, the water at that depth itself is not safe, and you are bringing gas and oil and whatever else up to the surface, so that cannot be safe in itself, let alone after acid fracking?

      There are some serious questions still to be answered aren’t there?

      No, acid fracking is not safe, in spite of some claiming it is and that we should not ask questions because we are not yet fully informed. I plan to remedy that, and thanks for assisting with these replies.

      The question really is after all this, just how unsafe is it?

      [comment edited at poster’s request]

  2. Hydrofluoric and hydrochloric acids immediately begin to neutralise when they are pumped in the open part of the well. The drilling company use a calculated volume and with the temperature present downhole it is neutralised within an hour or two leaving inert chemicals which are either circulated out of the well there and then, or come up later in the cleanup.

    Either way, all this laughable panic mongering is nothing but that, and not based on even basic memory of junior science. Pour some vinegar on a slab of limestone and see how long the acid remains acidic, not very long. The HCl used is not much stronger than domestic vinegar. It just serves to demonstrate how far removed the anti fracking movement is from even basic scientific literacy.

    • Not much point having the EA on board then, Martin Decker? Wasting taxpayers money checking ‘junior science’ experiments; p.s. we call it ‘primary science’ in the UK

      • Hi Sherwulfe, John Harrison did at least try, but Martin Decker we have met before, and just returns to the same old childish gross insult and overbearing bad temper in a rubbish diversion tactic. Transparent as their whole industry.

        I ask myself, would I want to have hydrofluoric acid put in the hands of these uneducated emotional children?

        Not a chance. Sad really.

        You notice not one question has been answered yet, they could not refute that hydrofluoric acid is not used by the water industry, which blew most of the “perfectly safe”diversions out of the water.

        So then this return to pathetic childish bad frack good frack bully mode rubbish gets them nowhere and just serves to detract from and destroy John Harrisons measured relatively intelligent posts.

        When the extremely relevant questions are answered maybe we will get somewhere [edited by moderator]

        Oh yes, for Martins information, acid reactions such as vinegar on limestone, or hydrofluoric acid on sandstone release toxic gas and the residue of released elements depending upon the strength of the reaction and the additional contaminants.
        Once again, try breathing the resultant gas and drinking the residue of either if you think it’s so harmless. I would not recommend it, just in case you are tempted.

        Back to square one, new balls please, start again.

        • Hi Phil. The point is we are dealing mainly with PR people here, they just spout the misinformation given to them by the companies and sadly are not able to move up the cognitive ladder and apply the hype to realise it cannot be real. They cannot be sympathetic, move on to empathy, as their jobs and mortgages are at stake. So for now we will have to endure the rhetoric until the industry, or something similar comes knocking on their doors and they realise it’s time to change jobs and switch sides. 🙂

          • Hi Sherwulfe, actually they do us a favour, they are so outrageously venomous and insulting they bring their entire industry into discredit and disrepute? I suspect many who are not sure either way, take one look at the insane extreme vindictive and insulting posts from these industry hacks and make up their mind immediately?
            No leave them where they are, they are doing a great job for us!

    • Martin

      The concerns re the use of acid are best laid out in the Katheryn McWhirter article on acidisation which is available in DoD.

      Other issues such as the need for a CEO to drink chemicals they produce in order to prove they are safe, or that the oil industry do not have a scoobie what is down there, are a diversion to the main argument.

      But fun to comment on … so I have just finished the housework for the morning. I bleached the toilet, but did not put my face in it to inhale the fumes, nor drink the contents of the bowl to prove then safe. I have also cleaned the oven using caustic soda, but again did not lick it to prove it safe,, nor put my head in the oven to deeply inhale the fumes, I read the instructions on the amazingly comprehensive data label on the bottle and took appropriate precautions.

      I then made up the (smokeless) fire, and once again did not put my head in the etc,ask the coalman to etc etc

      Back to the real world, i will look for more data on what comes up the well post an acid wash. These have been going on offshore in the UK for years, both the sarsons wash and the use of hydroflouric acid. However offshore it is not as problematic for onshore as I see it for these reasons

      1. All the flowback (waste) turns up in the process equipment. The water is separated out and then popped into the sea.
      2. there are no issues offshore re aquifer contamination by fracking ( no matter how remote a possibility etc out there) as there are no fresh water aquifers offshore.
      3. The safety of the workforce is under the HSWA and regulations, no member of the public is near the chemicals once they leave the dock on the ship.
      4. Blow outs offshore do not affect the public directly (and that means physically, not the affects on the families of any persons affected)

      For onshore all the concerns re aquifer contamination remain, with a bit of acid attached.

      Maybe we should comment on Katheryn’s concerns as a starting point for a suitable discussion. I think that is the idea of producing such a report and we can consider feedback as part of the peer review process?

      • Maybe hewes, instead of resorting to insults and childishness, the proponents of acid fracking could begin to regain some degree of credibility if they stuck to science and rationality.

        That way perhaps we could begin to get somewhere?

        Incidentally, leapfrogging comments to only reply to your own supporters, whilst refusing to address perfectly reasonable questions is no better, and simply reinforces the same abusive and insulting behaviour and gets us nowhere.

          • Sherwulfe
            I agree on that one. My wife and daughter pull me up regularly on my less than perfect kitchen cleaning routine, but I am the one with the least health problems. Mind you, I did have my tonsils out when I was 6, but I think it was all the rage. I always think of the slaughter house owner in all creatures great and small who, despite being covered in off meat was amazingly healthy.

        • Phil C
          Happy to answer questions if possible.

          For me ….

          Who said Hydroflouric acid was used in the water industry? I may have missed it in the rubric above.
          Has anyone said that the flowback from an acid job in an oil and gas well is not classed as toxic waste on exit from the well? Ie why would we expect anyone to class it as potable water?

          If we want to know what turns up at the wellhead, fair question, and worth rooting round for the answer. Then, how dealt with, stored, transported, treated and disposed of.

          • Hi hewes, in answer to both your questions,

            Apologies to you both, Paul and Ruth for quoting the following two posts, but evidence was requested and there is no other way.

            “Ken Wilkinson
            February 13, 2018 at 1:13 am
            What a fuss about nothing. Acidising is a bog standard technique that has a huge history with no issues. The acid reaction is very quick and the residues are harmless.
            Yet again we get people who know nothing passing comments on matters they do not understand.”

            “John Harrison
            February 13, 2018 at 5:20 am
            The technique of acidising has been used for over 120 years in both the drilling of water wells for drinking water and by the oil industry.
            The acid/water solution used for acidising by the drinking water industry in the UK’s limestone reservoirs (mostly chalks), is typically stronger than the oil industry use. It is usually 20% to 30% acid.”

            Not specific in definition perhaps, but indicative and implied by exclusion of differentiation of the difference between hydrochloric acid and hydrofluoric acid, and hence implies that they are both used by the water industry.
            Fortunately i know the difference and pointed it out, otherwise it may have been easily assumed that both were used by the water industry, and as we all now know, they are not.
            Only hydrochloric acid is used by the water industry, hydrofluoric acid however is one of the strongest acids on the planet and is an entirely different heavily corroded kettle of rapidly dissolved fish.

            Do you see how important it has become necessary to examine and question every word and phrase that comes from the ohandgee industry proponents and how failure to do so leads to what can only be termed as obfuscation and deception by omission?

            One could speculate about motives and agendas, to do just that, the consistent and pervasive attempts at personalisation of issues certainly reveals a concerted strategy.

            Questions? perhaps look back amongst the previous posts on this topic and you will find plenty of them.

            • Phil
              Thanks.
              Better for us to ask if they implied that Hydroflouric acid was used rather than guess.
              So ..if they are reading, ken, john, did you say that Hydroflouric acid was used in water treatment or not?
              Let’s see how that goes.

              Sorry to be picky, but assumptions are dangerous for us. As my mentor ( mentioned before ) said
              Trusties good, but checking is better, and, assume nothing. Advice that the anti fracking community seem to have taken to heart in spades.

              I will track back to look for other questions and get back to you.

  3. Re addition of Fluoride to water and those readers who may fear that a company is dosing their supply from a simply labelled container.

    The spec for the chemicals can be found in

    http://dwi.defra.gov.uk/stakeholders/information-letters/2016/01-2016-annexa.pdf

    This being the Code of Practice on Technical Aspects of Fluoridation of Water Supplies 2016

    The key section is 3.1

    3.1 Chemical standards
    Section 87C(2) of the Water Act 2003 permits the use of two chemical compounds to increase
    the fluoride content of water within an area subject to a fluoridation agreement. These compounds are:
     Disodium hexafluorosilicate (Na2SiF6); and
     Hexafluorosilicic acid (H2SiF6).
    European standards for disodium hexafluorosilicate (Na2SiF6) and hexafluorosilicic acid (H2SiF6) have been published. The BS:EN Standards specify the physical properties and purity criteria required of the compounds, together with test methods for sampling and analysis of the compounds; labelling; transportation; and storage instructions. Companies are reminded that the
    BS:EN standard does not include reference to the silicate content, which has been associated
    with storage or dosing issues.

    In order to be used in drinking water, these compounds must conform to either BS:EN 12174:2013 Sodium hexafluorosilicate or BS:EN 12175:2013 Hexafluorosilicic acid. Copies of these standards can be obtained from BSi Customer Services, (Tel: +44 020 8996 9000), or ordered from the BSi website: http://www.bsi-global.com.

    Water treatment chemicals which conform to a European Standard may only be used where the national conditions of use are observed. National conditions of use, where applicable, are detailed in the List of Approved Products for use in Public Water Supply in the United Kingdom published by DWI. Water undertakers in England and Wales shall refer to the most recent version
    of the List which is available on the DWI website: http://dwi.defra.gov.uk/drinking-waterproducts/approved-products/soslistcurrent.pdf for current information on national conditions of use.

    Code of Practice on Technical Aspects of Fluoridation of Water Supplies 2016 Page 4
    Water undertakers are expected to be aware of the contents of the relevant BS:EN standard for any fluoridation chemical used and must also ensure that adequate account has been taken of any additional guidance provided by the DWI.
    Section 88 of the WIA91 confers powers on the Secretary of State to make an order to add, or to remove, a compound to the list of permitted fluoridation chemicals.

    Re using a chemical from a sack or tub just labelled ‘Fluorine’ would be unusual as UK and EU regulations require that the chemical be labelled (as indeed are all those you all buy and read the lables on the chemicals you purchase ), and that the company produce a COSHH Assessment, based on the MSDS Sheet and how the chemical is used. Something that would be hard to do, for a substance perhaps labelled so simply and purchased maybe without any thought to what it actually is.

    For a view on why some think it is a good thing see link below

    https://www.bfsweb.org/fluoride-compounds-used-in-the-uk

    For an alternative view

    https://en.wikipedia.org/wiki/Water_fluoridation_controversy

    https://www.vice.com/sv/article/kwz5m3/why-are-governments-putting-fluoride-in-our-water-sheeple

    • Thanks hewes62,

      Well well, this is Interesting isn’t it?

      I notice the phrase “expected to be aware” in the “Water undertakers are expected to be aware of the contents of the relevant BS:EN standard for any fluoridation chemical used and must also ensure that adequate account has been taken of any additional guidance provided by the DWI.”

      Its the same self regulation situation again isn’t it? We all know what that leads to.

      This is a web site that indicates that something is severely wrong with the use of fluoride in USA and UK domestic water supply, it also indicates that fluoride is a waste product of phosphate mining often from China and the fluoride and fluorine that is derived there, this is what it says about the source, and the reason it need to be disposed of, and why it is sold to water companies in USA, it is a similar story here.

      “Fluoride In Water

      Corporations have a lot invested in fluoridation, which allows them to dispose of industrial pollution via dilution. Today, the most common product used for fluoridation is hydrofluosilicic acid, which is not a natural substance but a waste product coming straight from the scrubbers of the phosphate fertilizer industry. When phosphate is mined, they have to get rid of the attached fluorine or it would kill the plants. So they put the phosphate through a sulphuric acid wash to separate the fluorine out into what is called hazardous waste liquor. The fluorine is captured by a scrubber system since they can’t let it go out into the air because it would kill all the plants and animals around.
      If they had to dispose of this liquor as hazardous industrial waste, it would cost them $1.40 a gallon or more neutralize it, depending on how much cadmium, lead, uranium, and arsenic are also present. They don’t want to pay that, so instead they call it a product and we pay them approximately 3 cents a gallon to dump in our water. Data collected in the largest survey to date–of over 39,000 American schoolchildren ages 5 to 17 in 84 communities, showed that children living in fluoridated areas had tooth decay rates nearly identical with those living in unfluoridated areas.”

      “It is now known – thanks to the meticulous research of Dr. Jennifer Luke from the University of Surrey in England – that the pineal gland is the primary target of fluoride accumulation within the body.”

      http://humansarefree.com/2010/12/fluoride-most-toxic-substance-for.html

      It is interesting also that there are certain uses for hydrofluoric acid in the pharmaceutical industry, and one of the resulting products is Prosac, hence the use by the nazis, and USA and UK and no doubt EU, as a cognitive suppressant to prevent the population rebelling against the endemic political and corporate interests insanity.

      • Phil
        I disagree with you take on regulation.

        The regulation of the water industry is based on the UK model of regulation, which is mainly risk based, but leans to prescription in various areas.

        It has led to us being the envy of most of the world.

        I would add that my bona Fidel are, in brief, working under the prescriptive mines and quarries legislation, and having been inspected by HM inspectorate in that industry. We were inspected maybe 4 Times a year.
        I have worked as an offshore inspector for the HSEx, under the risk based HSWA and Safety Case Regulations. That includes writing letters to companies post inspection, tue consideration of or issue of improvement or prohibition notices and working with with the procurator fiscal where it was considered that prosecution was in order ( in Scotland ). Then in the OG industry was inspected by the EA, HSEx under the various regs.
        I have audited Various industries under ISO 114001, OHSAS 18001 and ISO9001.
        I have worked in the power industry abroad as well as O&G and have experience of the regulatory framework in Europe, Vietnam, Singapore, Ex Russian Federation Countries, Australia, Norway and NZ.

        So, I think UK Legislation has a suitable framework, better than most of the rest of the world.

        What I would as is

        1. Can you name a couple of examples of industries in the UK that are not ‘self regulated’
        2. Can you name a country or two where industry is not self regulated, and a comment on its superiority to the UK. Ie show that the alternative to what you call self regulation is a suitable place to be led to.

        • Hi hewes62, sorry i didn’t mean to leapfrog your post, i would rather not reproduce that trend, but i had all ready partially written a reply to Johns post, so it went first.
          Oh yes, regulation, self or supervised, or none at all.
          I think i have a different opinion to yours regarding regulation because i have learned, relatively recently i might add, that there are concerted efforts to reduce such controls from central organisations, such as the EA, by severely economical crippling and essentially high jacking the organisation to act as little more than a rubber stamp farce of a shadow of its former self.

          We see exactly the same process happening in USA as Trump is economically crippling the EPA and putting a non qualified person in charge to run it. If anyone ever wondered why regulations in USA are not working, they may only need to look there.

          The result of that crippling of any penalty measures here in UK, is that companies, corporations, banks and government itself are now finding they have almost no penalties to suffer at all, and therefore regulations and safeguards are ignored in almost every scenario.

          We see that all the time in action with the operators of onshore ohandgee activities who now act as if there are no regulations whatsoever, and even when they do get a mildly rapped knuckle they just laugh and ignore it because there is no penalty for failing to comply and they do whatever they want time and time and time again. If we are lucky they may say sorry, and get a stiff letter, but behind our backs they are laughing all the way to the bank. That is what self regulation has become.

          The result is obvious and deeply insulting to the rest of us. So we object and we say so, but its not they who get taken to court, its us who object to them not obeying any regulations? And you wonder why we get annoyed and point it out to only receive insults and abuse from the PR hacks?

          Then you say you dont agree with me saying i don’t approve of self regulation? Really? Seriously?

          The forces that have brought this debacle about, appear to be economic, political and perhaps less obvious forces at work in almost all levels of society, from companies and corporations and political and economic organisations. These forces are distorting the erstwhile trustworthy and at least strongly regulated controls and arbiters that organise and regulate our everyday life.

          It is chaos, it is pernicious and its totally destructive of any real value that a so called 1st world democracy should be standing up for.

          The example of the co-opting of the police into some sort of private protection agency apparently having their strings severely tugged by agencies within their own hierarchical structure, only seeming to see the protesters and totally and criminally turning their backs on all the operators and even being complicit in their breaking of the very laws the police are supposed to be there to protect and uphold.

          where are the court cases for failure to obey and comply with safety regulations, planning regulations, operational traffic management plans and private security running amok and assaulting the public? Let alone their own misuse of their tax payer given authority in any protest to protect their community, their land, their health, their water, their land and their future and to protect everyone else in the same way?

          No, they find themselves in court and the operators get away with…..ecological murder.

          That also is a self regulation issue of the police activities themselves is it not?

          So hewes62, disagree with me if you wish, but when these worrying trends all join together and get totally out of hand and we all find ourselves under the frackboot of a totalitarian regime, that could have been stopped now, if we had the guts to do so, dont say i didn’t try and warn you.

          • Phil C
            No worries, I was not hot on chemistry.
            Re regulation, it’s what we have. It can always be better, and if required more effort put into aspects that concern people the most.
            If fracking were illegal ( as per where there is a moritorium ), then I doubt it would be done, likewise if anyone bans onshore O&G exploration and drilling, I doubt anyone would be doing it.
            All it needs to do that, it seems, is a change of heart by the present gov, or a different party in power. The same police will oversee it either way I guess.

      • Phil C, your last paragraph indicates that you are a conspiracy theorist. Hardly a qualification for a serious debate about public health issues.

        “It is interesting also that there are certain uses for hydrofluoric acid in the pharmaceutical industry, and one of the resulting products is Prosac, hence the use by the nazis, and USA and UK and no doubt EU, as a cognitive suppressant to prevent the population rebelling against the endemic political and corporate interests insanity.”

        How can you expect people to take you seriously when you make such bizarre claims?

  4. Hydrofluoric acid is not used by the water industry simply because it is not suitable to dissolve limestone, It is used by the oil industry to dissolve sandstone.

    That was my statement, where did I imply that the water industry use it Phil?

    Could you also be kind enough to inform us which toxic gasses are give off when you apply Hydrofluoric acid to Sandstone and Hydrochloric acid to Limestone?

    • Hi John,
      No of course you didnt say that, and i didnt say you did say that, i mentioned it only because the reference to the water industry would have indicated without the distinction between hydrofluoric acid and hydrochloric acid that it was a part of the process, i would not have referenced your post at all, but for hewes62 request for a reference post, and i did explain that it was not said by you, but perhaps implied, which is why i made the distinction in the first place.
      I am looking out my old reference books and i will do an internet search for the gases that result from various acid reactions to various materials, so i’ll get back to you on that.

      Hydrochloric acid reaction to limestone is a result of the fact that acids react to alkalis in a spectacular way: in that calcium carbonate + hydrochloric acid → carbon dioxide + calcium chloride + water
      CaCO3 + 2HCl → CO2 + CaCl2 + H2O

      The acid of vinegar is acetic acid which is one of the weaker acids: CaCO3 + 2CH3COOH –> Ca(CH3COO)2 +H2O +CO2

      Both mild reactions and since the target elements and acid are not in themselves toxic, the result is fizz and water and C02.

      So far so good.

      Then we get to hydrofluoric acid and it reacts to various materials. hydrofluoric acid actually breaks down the bonds of elements due to its highly corrosive reaction to almost any material including silica, which is why you cannot contain hydrofluoric acid in glass containers:
      HF(aq)⟶F−⋅… H3O+HF(aq)⟶FX−⋅… HX3OX+Thus HF(aq) has a depressed pKa in water whilst its “real acidity” can be much higher.Homo-association of HF only occurs in very high concentration (close to unity). You can estimate the extent of homo-association of anhydrous HF by measuring its conductivity. Anhydrous HF has lower conductivity (<1.6 μμS/cm) than deionized water (~5 μμS/cm) [1] so it's probably not terribly important in driving disassociation of HF, esp in water.
      HF causes deep burn, often with a delayed onset because while the skin prevents charged raw hydronium ion from penetrating too deeply, HF or the hydronium-flouride ion pair can be absorbed and releases the hydronium ion (by exchanging with water abundant in tissue) at deeper level. (Thus it's often reported as more painful than other acid burn)
      Although fluoride in ppm level is anti-microbial and prevents cavity (by reacting with calcium mineral in tooth), high concentration of fluoride is toxic because, as cited in previous answer, fluoride interferes with calcium metabolism in forming insoluble calcium fluoride. It causes skeletal fluorosis and suppresses some essential metabolic enzymes.
      HF is corrosive because of its proton; it's corrosive to bones because of its fluoride. HF corrodes glass and HCl doesn't because silicon tetrafluoride is a more stable complex than the highly reactive silicon tetrachloride. It has little to do with whether the acid is weak or strong.

      "HF(aq), like other hydrogen halides, does completely give up its proton to H2OHX2O but since F is the most eletronegative element on earth, it will pair up with hydronium ion in the aqueous environment, making the proton "less available", at least to a pH electrode. This is one of strongest hydrogen bond known."

      https://biology.stackexchange.com/questions/1977/why-is-hydrofluoric-acid-so-dangerous-if-it-is-a-weak-acid

      "Hydrofluoric acid is a highly corrosive liquid and is a contact poison. It should be handled with extreme care, beyond that accorded to other mineral acids. Owing to its low dissociation constant, HF as a neutral lipid-soluble molecule penetrates tissue more rapidly than typical mineral acids. Because of the ability of hydrofluoric acid to penetrate tissue, poisoning can occur readily through exposure of skin or eyes, or when inhaled or swallowed. Symptoms of exposure to hydrofluoric acid may not be immediately evident. HF interferes with nerve function, meaning that burns may not initially be painful. Accidental exposures can go unnoticed, delaying treatment and increasing the extent and seriousness of the injury.
      Once absorbed into blood through the skin, it reacts with blood calcium and may cause cardiac arrest. Burns with areas larger than 25 square inches (160 cm2) have the potential to cause serious systemic toxicity from interference with blood and tissue calcium levels. In the body, hydrofluoric acid reacts with the ubiquitous biologically important ions Ca2+ and Mg2+. Formation of insoluble calcium fluoride is proposed as the etiology for both precipitous fall in serum calcium and the severe pain associated with tissue toxicity."

      http://www.corrosion-doctors.org/Acids/Hydrofluoric.htm

      "The 2 mechanisms that cause tissue damage are corrosive burn from the free hydrogen ions and chemical burn from tissue penetration of the fluoride ions. Fluoride ions penetrate and form insoluble salts with calcium and magnesium. Soluble salts also are formed with other cations but dissociate rapidly. Consequently, fluoride ions release, and further tissue destruction occurs.

      Anhydrous hydrogen fluoride and hydrofluoric acid are extremely corrosive to all tissues of the body. Skin contact results in painful deep-seated burns that are slow to heal. Burns from dilute (<50%) HF solutions do not usually become apparent until several hours after exposure; more concentrated solutions and anhydrous HF cause immediate painful burns and tissue destruction. HF burns pose unique dangers distinct from other acids such as HCl and H2SO4: undissociated HF readily penetrates the skin, damaging underlying tissue; fluoride ion can then cause destruction of soft tissues and decalcification of the bones. (reference)

      Hydrofluoric acid and HF vapor can cause severe burns to the eyes, which may lead to permanent damage and blindness. At 10 to 15 ppm, HF vapor is irritating to the eyes, skin, and respiratory tract. Exposure to higher concentrations can result in serious damage to the lungs, and fatal pulmonary edema may develop after a delay of several hours. Brief exposure (5 min) to 50 to 250 ppm may be fatal to humans. Ingestion of HF can produce severe injury to the mouth, throat, and gastrointestinal tract and may be fatal. Hydrofluoric acid is a clear, colorless liquid, miscible with water, with an acrid, irritating odor. It is an extremely corrosive liquid and vapor that can cause severe injury via skin and eye contact, inhalation, or ingestion."

      "Excessive exposure to sulfur hexafluoride may affect the brain. The main impact of sulfur hexafluoride on the environment is as a greenhouse gas, influencing climate change. Consequently sulfur hexafluoride is controlled under the Kyoto Protocol. Of the internationally monitored greenhouse gases it has by far the highest global warming potential (23,000 times that of carbon dioxide), however it is only released in small amounts. Due to its stability it has a very long atmospheric lifetime."

      Reaction with all the elements materials and additives and chemicals in the operation of acid fracking will have unknown effects and the combination of one or more elements, materials, additives and chemicals can only add to the unknown factors that will result in hydrofluoric acid use.

      [Comment amended at poster’s request]

  5. “I still have doubts about the residues and gasses produced by acid reactions to rock strata and the attendant chemical additives, material intrusions and constituents that such activities inevitably produce as a by product and as part of the procedure.”

    The reactions for the acidising are-

    calcium carbonate (Limestone)+ hydrochloric acid → carbon dioxide + calcium chloride (Salt) + water

    CaCO3 + 2HCl → CO2 + CaCl2 + H2O

    CaCO3 + 2HF→ CaF2(Calcium fluoride) + H2O + CO2

    Acidising has been carried out in the Weald, in Dorset and in the Midlands for many years.

    With your views against acidising Phil, I look forward to your concerns and protest against the geothermal wells that are to be drilled in Cornwall that will be using a Hydrofluoric acid treatment.

    • Thanks John,
      See above, have you investigated the effects of hydrofluoric acid reaction and gases and residues that result from all the materials, additives, chemicals and elements used in the operation of acid fracking?

      As to my opinion of its use elsewhere, then this post subject may well raise some important questions about its use, and similarly in geothermal wells in Cornwall, perhaps that ought to be re-examined and a safer method proposed?

      • Have you ever thought that the other chemicals may have been carefully selected or designed, so that they don’t take part in the acid/Sandstone reaction?

        • Hi John, thanks, i think that goes back to what we were saying earlier, that nothing should be taken for granted when examining such claims from an organisation that seeks to profit from the ignorance of the misinformed and criminally uninformed public?
          I am disinclined to acquiesce to that presumption.

          That means “No”.

  6. Regardless of Acid what about the pesticides that are sprayed on the fields by farmers !!
    This is far more widespread and damaging to the environment.
    You worry about a little oil wouldn’t your attention be best directed to improving farming methods to make them more
    environmentally friendly ?

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