Industry

Cuadrilla calls for new approach to fracking earthquake rules

Old DECC TLS

Part of DECC infographic on Traffic Light system (2014). Source: OGA

Cuadrilla called today for changes to the regulations on seismicity induced by fracking to take account of ground vibration.

The company has said current regulation, called the traffic light system, makes shale gas commercially unviable. It is based on the magnitude of tremors and requires fracking to pause if it induces seismicity measuring 0.5ML or above.

Cuadrilla’s fracking operation at Preston New Road, near Blackpool induced more than 50 small tremors in autumn 2018. The company paused operations at least five times.

190404 WEETF Francis Egan (2)

Francis Egan (right) with seminar chair, Lord Truscott, 4 April 2019. Photo: DrillOrDrop

Speaking at a seminar in London this morning, Cuadrilla’s chief executive, Francis Egan, said:

 “We are not calling for a number, as in should it be 1, 1.5 or 0.75.

“In fact, we think that is too crude a system.

“As far as somebody standing on the surface is concerned, 0.5 does not mean anything.

“What matters to them is ‘is the ground vibrating? Can I feel it? Is it doing any damage?’.

“At the very least a TLS [traffic light system] should include a measurement of ground vibration, which is, in fact how other industries that cause vibration, including construction and mining are regulated.”

Cuadrilla and Ineos have both called for a review of the traffic light system. The government has said this is the responsibility of the Oil & Gas Authority.

The OGA confirmed again today that no review was underway. It is, however, analysing data collected during fracking in Lancashire.

In February, Cuadrilla said there was “more than ample evidence to justify a technical review of the regulations”. It added that subject to the outcome of the review, the company would complete fracking of the first well and frack the second at Preston New Road.

Mr Egan defended the company today against suggestions that it had not complained about the traffic light system until the earth tremors last year.

The energy minister, Claire Perry, said in a letter to Cuadrilla, in November 2018:

“I note that your Hydraulic Fracture Plan was developed and reviewed over several months with reference to existing regulations, including the traffic light system and at no point did you communication that it would not be possible to proceed without a change in regulations”.

Mr Egan told the seminar:

“Proceeding of itself is not the issue. The issue is producing commercial hydrocarbons.

“We have been very clear as Cuadrilla that we believe it is not possible and we were very clear before that letter.”

He declined to say what level of seismicity would allow commercial production of shale gas.

  • Mr Egan were speaking at the Westminster Energy, Environment & Transport Forum keynote seminar on Unconventional oil and gas market in the UK – planning changes, environmental regulation and tackling the scale-up challenges

Reporting from this event was made possible by individual donations from DrillOrDrop readers

 

46 replies »

  1. Still waiting for the Independent Well Examiners report.
    It’s not surface vibration, but seismic activity that damages the well integrity that is the issue here. Cuadrilla are always trying to ignore this inconvenient issue.

    • Swift – it is only an issue in the minds of people who know nothing about the subject. Wells experience shear failure all of the time and don’t leak because the companies know that shear failure is a possibility so they ensure that the casing is well cemented. Before writing such nonsense maybe it would be worth finding some examples to back up your argument.

      • ‘ the companies know that shear failure is a possibility so they ensure that the casing is well cemented. Before writing such nonsense maybe it would be worth finding some examples to back up your argument’.

        Taken from an FOI between HSE and Cuadrilla after (yes after) the Preese Hall failings

        “Cuadrilla were looking for some guidance on when a cement bond log was required and who was responsible for the interpretation of the logs. We advised that in a goal setting regime that it was the operator to establish the criteria for when they would run a CBL for surface, intermediate, and production casing. The criteria should be documented and then we could then inspect your operations against this standard”

        And when they finally got round to doing a cement bond log, a job they didn’t do before they started fracking Preese Hall,

        “From our 5.5 inch bond log we have identified some questionable cement bonds”

        Worrying correspondence from a company who publicly claims,

        ‘Members of Cuadrilla’s management team have each played leading roles in the drilling and/or hydraulic fracturing of more than 3,000 natural gas and oil wells across the world.’

    • Ha! Ha! A TLSexit?

      Or perhaps a Flextension?

      A hard or a soft TLSexit?

      Or no TLSexit at all?

      Will there be a hard or soft border between geologic zones?

      Perhaps we should have a referendum?
      That should take three years of nothing and embarrass everyone and get precisely nowhere very very slowly…..

      It’s a gas isn’t it!

      That’s six exclamation marks hewesamuse.

      What fun! I did enjoy that!

      Oh yes, and three exclamation marks…..

  2. I presume Mr Egan explained in detail about what the BGS had to say about the events at Preese hall and why a 1.7ML was proposed after the Blackpool earthquakes.

    ‘Nevertheless, we consider that the maximum magnitude threshold of 1.7 ML, initially proposed for the traffic light system, is undesirably high from the viewpoint of prudent conduct of future operations. Based on this limit, no action would have been taken before the magnitude
    2.3 ML event on 1 April 2011 Instead, we recommend a lower limit of 0.5 ML’

    • I wonder if this part of the official review of the events at Preese Hall was covered in detail?

      ‘The initial threshold for cessation of operations proposed was 1.7 ML. This was based on the critical magnitude 2.6 ML and a maximum post-injection magnitude increase of 0.9 ML. However, we note that, based on this limit, no action would have been taken before the
      magnitude 2.3 ML event on 1 April 2011’

      Seems strange to now be saying “We are not calling for a number, as in should it be 1, 1.5 or 0.75″

  3. An excellent review of Traffic Light Protocols & their need for review can be found here;

    “Technical meeting on the traffic light protocols (TLP) for induced seismicity: summary and recommendations” Geological Survey of Canada Open File Report 8075

    A technical meeting was held on October 6, 2015, at the downtown campus of the University of Calgary to discuss the effectiveness of the traffic light protocol (TLP) approach for management of risks from induced seismicity. The meeting was attended by 64 participants from industry (55%), various government agencies (25%), academia (10%), and professional societies (5%). The role of TLP in the mitigation of seismic hazards from induced seismicity and its challenges were examined. Three major issues with the current magnitude-based TLPs were identified: (1) possible confusion due to the magnitude uncertainty for an induced seismic event, (2) lack of a link to the impact/consequences of reported seismic event(s), and (3) need to integrate other potential hazard indicators. To improve the effectiveness of existing TLPs, the following changes are recommended: (1) incorporate ground motion information into TLPs such that decisions can be made based on better assessment of the actual risk, (2) develop a standardized approach for earthquake magnitude calculation, and (3) make the TLPs more adaptive to local hazard conditions through research and incorporation (as appropriate) of other hazard indicators. A number of action items were brought forward at the workshop: (1) establishing a uniform standard for seismic data collection and assessment, (2) establishing a coherent framework of data sharing for induced seismicity monitoring and research, (3) sharing other types of data, such as locations of known faults, and (4) taking more proactive approaches to establish best practices and to mitigate seismic risk from induced seismicity. These actions will greatly strengthen the reputation of the hydrocarbon industry with respect to proactive, sensitive and responsible development of unconventional sources. If these steps can be implemented in a timely and effective manner, Canada has the potential to be a world leader in monitoring, understanding and mitigating hazards and risks from injection-induced seismicity.

    Link is here & is open access. https://doi.org/10.4095/299002

    This report was one of the main pieces of evidence that I recommended to the APPG on shale gas meeting last Tuesday (2nd April) revision of the TLS.

    • Dr Riley that meeting took place in 2015. Why were you and Cuadrilla not jumping up and down 4 years ago and demanding that our own system be updated? You all seemed quite content with our existing system until 18th October 2018.

      In fact one leading academic even went on record saying “We have to look whether we can produce safely and in economic conditions under the permitting legislation in this country. *I believe we can do that*.” (My emphasis)

      That permitting legislation does of course include the TLS.

      It seems that now we are supposed to believe that you all knew ages ago that the system was flawed and needed to be changed but said nothing. Isn’t it a bit too late for you to be referring back to 4 year old documents and trying to press them into service when you all ignored them at the time?

      Our esteemed member of parliament for Fylde put this well:

      “One of the changes that came in was a traffic light system—red, amber and green—and we have seen seismic events triggered at Preston New Road in recent days. Four of those events have been classed as red events, and have led to a cessation in activity. I put it to the Minister that for six years, the industry was not approaching me or anyone else to say that the threshold was far too low, but we now hear calls that a seismic event should need to be a 1.5 or a 2 to trigger a red event. I am sorry, but that ship has sailed. The industry had six years to make the case for that, and no case was made.”

      • Refracktion. It was Oct 2015 when the meeting was held. Canada has much more experience than us. Please read the report & learn from it.

            • Refracktion, I have not ignored anything. The TLS was always set at a very low level in the UK until further information became available. It has, not just the above report (and further information since), but also the first horizontal frack in the Bowland Shale. Have you read the GSC report yet? If you did you would see it has a very good & flexible approach to defining the TLS at different levels in different settings, even in the same juristiction.

              • Dr Riley. If you did not ignore it why are you only bringing to to people’s attention this week? Why did you not argue this case 3 years ago? It’s a real puzzler that!

                As I pointed out above, you even stated that the existing situation allowed for safe and economic production.

                • It was less than 3 years ago when the GSC report was released & horizontal fracking of the Bowland Shales has only been undertaken in the last year & it demonstrates that 0.5ML is too low to gain any robust exploration knowledge. Hence the need for review. Have you read the report yet???

                • Refracktion you have claimed I said “As I pointed out above, you even stated that the existing situation allowed for safe and economic production.” I have never said that. It may have been said, but NOT by me.

                • Well it clearly states here https://drillordrop.com/canterbury-debate-dr-nick-riley-mbe/ that you said:

                  “We have to look whether we can produce safely and in economic conditions under the permitting legislation in this country. I believe we can do that.”

                  Or are there perhaps two Dr Nick Riley MBEs and it was the other one who said this?

                  As to “horizontal fracking of the Bowland Shales has only been undertaken in the last year & it demonstrates that 0.5ML is too low to gain any robust exploration knowledge” that’s funny given that Mr Egan said

                  “We have acquired almost 40,000 micro-seismic data points during hydraulic fracturing operations on the PNR1-z well. We believe this to be the most comprehensive micro-seismic data set ever collected at a shale gas well anywhere in the world. The data has been shared with the OGA and the British Geological Survey (BGS) and we believe that there is more than ample evidence to justify an expert technical review of the TLS and, based on the outcome of that review, a revision at the PNR site, without compromising on safety.”

                  So you are claiming there is not enough evidence “to gain any robust exploration knowledge”, but Francis Egan is saying there is “ample evidence to justify an expert technical review of the TLS”. Maybe the two of you need to have a chat and get your stories straight?

                • What you quote from the Canterbury debate is different to what you originally stated I said – which was a long time ago! It was a conditional statement ““We have to look whether we can produce safely and in economic conditions under the permitting legislation in this country. I believe we can do that.” The word “whether” denotes uncertainty & “I believe” was an opinion based the evidence available at the time. The evidence now demonstrates that 0.5M limit is too low for economic production. I get the feeling you are just disinterested in learning that much more is known now as I have pointed out previously in this thread.

                • Refracktion – I see you did not quote me in full from the Canterbury debate. What I said was definitely conditional on drilling futuere exploration wells and conducting frack tests.

                  “We have to look whether we can produce safely and in economic conditions under the permitting legislation in this country. I believe we can do that. We have to have exploration wells and we have to have frack tests. It is a wonderful opportunity for this country and I would hate it to be lost because of misinformation from certain campaigners. And by the way, I am pro-renewables as well”

                  That’s whole point of exploration and testing Refracktion, to learn by doing!

                • Dr Riley, that is what our friends at Private Eye would refer to as a classic “reverse ferret”. 😂 Excellent! You are of course quite entitled to change your position but I really think you should acknowledge the fact that you are doing it.

                  I am quite happy to learn although I always marvel at the apparent contradictions of an industry which tells us we shouldn’t read across from the Americas when it comes to harms yet draws analogies from production and or other experience when it suits them.

                • Refracktion you quote Mr Egan claiming that we are not saying the same thing.

                  ” So you are claiming there is not enough evidence “to gain any robust exploration knowledge”, but Francis Egan is saying there is “ample evidence to justify an expert technical review of the TLS”. Maybe the two of you need to have a chat and get your stories straight?”

                  We are saying the same thing & that there is ample evidence to justify an expert technical review of the TLS

                • Refraktion – it’s really not too difficult to understand why some aspects of shale gas production are relevant to the UK situation and others are not. For example, surely even you must acknowledge that it’s stupid to use examples of leakages from storage pools when they will not be allowed in the UK or to site the danger of chemicals that are used in the UK but won’t be allowed to be used here or the licensing structure in the USA that forces overproduction which is totally different to the UK. On the other hand, one can learn from the behavior of potential analogues such as the Bakken to the Kimmeridge – it’s really not so difficult or puzzling is it? But I guess it’s such an good opportunity for onehobsmanship that it can’t be missed

                • So Refraktion have you read this carefully yet ““Technical meeting on the traffic light protocols (TLP) for induced seismicity: summary and recommendations” Geological Survey of Canada Open File Report 8075”. There is no sign in anything you have posted that you have. All you have tried to do is discredit me. Why not try & discredit the Geological Survey of Canada Report with some good technical discussion? Is it beyond your capacity to do that?

                • Of course Judith – there are some analogs which don’t apply. Correct. Who did you say you really were again?

                  Dr Riley – I hadn’t realise that there was a test at the end of this – apologies. Yes I read the report early this morning after you posted it. It seems to concentrate on felt seismicity doesn’t it. Unless I missed it (and I did read it quite quickly) it didn’t really mention underground impacts at all, and that is an important factor in setting the UK TLS isn’t it?

                • Refracktion, It is impossible to read it quickly & analyse what it says, even for an expert. It does say ground vibration is an important aspect for the TLS, but it says a lot more than that. Even reading the summary, which I cut & pasted into my post – so the headline recommendations were easily accessible for those who could not, or did not want to, download & read the full report, would tell us more about the report’s contents than what you have just regurgitated. So still no in depth technical debate coming from you about the report & the need to have TLS reviewed & changed (not just ours, but theirs too).

                • Sorry Dr Riley. I’m not sure I follow you. Are you saying the Canadian report DOES address subsurface seismic activity and that in my amateur reading I missed it then?

                • Refracktion, There is a really good programme on Radio 4 called “last words”. It is not a word game.

                • Golly Gosh Dr Riley. I was really expecting a more sensible response than that from you with all those letters after your name!

                  How long before they feature Cuadrilla on that programme do you think? 😉

                  Maybe you could share some of your favourite prog rock music videos with us here? Here’s one of mine. I know what I like in your wardrobe (and it’s not Cuadrilla)

    • But when asked neither you or Brian Baptie were able to come up with any better reason for raising the thresholds other than;
      1. It’s an experiment, we won’t learn anything unless we increase the limits.
      2. PNR/ Little Plumpton is a sparsely inhabited area.

      Neither of which is reasures either residents or their MPs.

      Your evidence that a natural 7 ML earthquake in Japan didn’t damage a borehole was weak since since this is a poor analogy for an induced earthquake where the well is bored through the fault that moves. That and the fact that Cuadrilla’s PH-1 well was abandoned due to deformation caused by much smaller 2.3 ML event (induced by themselves).
      The review that established the TLS did leave room for increases in the thresholds but when it could be demonstrated that the operator understood the geology etc. That hasn’t happened yet.

      • Dorkinian, there are many reasons why the limit should be reviewed and these include:-

        1) The limit is far lower than anywhere else in the world
        2) If the limit is applied to other activities that cause tremors then we will seriously impact our ability to generate and store renewable energy
        3) The initial limit was based on the false assumption that a 0.5 Ml threshold separated tensile from shear fractures
        4) We have far more data and understanding most of this comes from the USA but also from the UK
        5) Seismicity associated with fracking has never been an issue except in tectonically active areas
        6) Local magnitude is a poor measure to assess risk – ground velocity is far better and is standard in other industries

  4. “The issue is producing commercial hydrocarbons. We have been very clear as Cuadrilla that we believe it is not possible and we were very clear before that letter.”

    I have to admit to be struggling to find any reference to Cuadrilla having made it very clear before they started causing this set of tremors, that commercial production would be impossible with a 0.5Ml trigger.

    Do you think he is being a tad disingenuous here and is talking about the few days in between realising what a problem they had given themselves by helping to design the TLS and then receiving the snub from government in that letter?

  5. The issue is of the combined effect of multiple earthquakes, both on the surface and equally important underground, on utilities, fracking equipment integrity and ground integrity.
    Preese Hall fracking equipment was damaged by repeated earthquakes and massive amounts of contaminated fluids eventually dumped into the Manchester Ship Canal by Cuadrilla without penalty!
    However Climate Destruction means that none of these fossil fuel extraction and combustion activities should be taking place anywhere!

    • Peter K

      What fracking equipment was repeatedly damaged at Preese Hall? I note that the well deformed but not that the frack pumps, tanks, coiled tubing etc etc were damaged at all or repeatedly?

      The treated fluids were disposed of into the canal, and no penalty needed for that lawful activity, although since then that specific disposal rout is not allowed. ‘Massive’ is a relative construct so it could be termed as a small legal disposal of frack fluid?

      • Hewes62,
        The quantity of contaminated radioactive waste water dumped into the Manchester Ship Canal without penalty after being classified as Industrial Waste water was actually in the region of a massive TWO MILLION GALLONS.
        So much for Gold Standard Monitoring!
        The damaged equipment was enough to require the fracking process to be stopped and the waste water dumped unceremoniously!

        • Peter – it was not radioactive waste – two million gallons of fluid that has concentrations of elements slightly above that of the baseline is not a danger to anyone.

          • Actually it they did dump radioactive waste water (which is what Peter said wasn’t it?) The EA measured up to 90bql /l didn’t they?.

            While that isn’t exactly Fukushima level it is still 90 times the level allowable for unpermitted disposal so it should not have been put into a public watercourse without treatment.

            • Refracktion
              It was permitted disposal at the time.

              Plus it went through the treatment plant.

              https://www.bbc.co.uk/news/uk-england-25902272

              The level was measured as 90 times that for drinking water it seems.

              I will have to look back to see what treatment was applied ( if any ), other than dilution. As noted as there is a high discharge rate in excess of 1000gps from the plant.

              https://frack-off.org.uk/support-sites/davyhulme/

              However, some reporting gives the impression that Cuadrilla rocked up to the canal and popped 2 million gallons into it directly, without permission, which is not the case.

              Good that the regulations have changed, and I do not expect that type of discharge ( of frack water through Davyhulme into the Manchester ship canal ) will happen again.

              • “It was permitted disposal at the time”

                – true

                “Plus it went through the treatment plant”

                – true but I am not aware that they treated the radioactivity. As far as I can tell the reason that Daveyhulme would not be used now is that they don’t have the facilities to treat it.

                “The level was measured as 90 times that for drinking water it seems”

                – I thought the 90 x reference was to the concentration in Becquerels per litre (1 bql/l in the case of Ra226+) allowed for unpermitted disposal – but it may also be the same level permitted in drinking water?

                https://www.sepa.org.uk/media/101532/guidance_for_norm_industrial_activities_on_how_to_comply_with_the_radioactive_substances_exemption_regime.pdf

                I think we can be pretty sure it will not be discharged into the ship canal again. The conundrum is where it will end up given that the Cuadrilla appeal heard that even the exploratory drilling in Lancashire would use up the majority (65%- 68%) of treatment capacity and a 2017 study concluded that there was no co-ordinated strategy for the management of liquid fracking waste in the UK. I’m not sure a lot has changed since then. If it has I would be interested to know how.

                • Refracktion

                  Yes … how and where large amounts of frackwater will be disposed off is yet to be determined.

                  My own opinion is that the issue will remain one of small scale disposal from exploration and appraisal wells until the industry scales up, or not.

                  If it scales up, then it will address the issue by building capacity / re use / whatever, but in the meantime it is not as pressing as working out how to frack within existing guidelines.

        • Peter K

          The discharge capacity of the Davyhulme works is some 5570L per second, or 1230gallons per second.

          The frack water would take 30 minutes to discharge if it were the only discharge, or constitute 2.4% of the daily discharge if discharged in 1 day ( or less than 1% if commingled over 3 days ).

          But if the headline were …. Cuadrilla frack water constitutes 2.4% to Davyhulme discharge over 1 day it may not be so exciting.

          Maybe it should be … Davyhulme plant dumps 96 Million gallons of waste into the Manchester Ship Canal Daily, and on 1 day 2.4% of that was frack wastewater.

          Hence my thought that, in what is discharged daily ( or dumped if that is the common term for discharge ) the frack water amount was not massive. But size may be in the eye of the beholder.

          Again, I note that this was a legal discharge, so a penalty would not be in order in this specific case.

          I would also note that the cessation of fracking at Preese Hall did lead to the returned frack fluid being sent for treatment. However, has fracking not been suspended, at some time the fluid ( maybe more ) would have been despatched for treatment.

          Re damaged equipment, I see that there were well issue, but not that fracking equipment was damaged by surface or underground seismic activity.

          https://unearthed.greenpeace.org/2015/06/15/energy-files-cuadrillas-preese-hall-fracking-well-had-to-be-plugged-again-after-more-issues/

  6. “Induced more than 50 small tremors”!!!

    Thanks Ruth.

    Doesn’t sound so scary.

    How many would be produced at much greater magnitude to blast huge quantities of granite out of Cornwall to produce a tidal lagoon at Swansea? Alternative tremors, okay? Trashing local democracy, okay?

    Ronin-red flags were initially agreed for motor cars. And then, improvements were made.

  7. Its ok to talk about Canada…. or the US or anywhere else, people do learn the generality of what can happen for example the very evident clusters of seismic events in Ohio, or the Netherlands, but we are talking specifically about the geology here in the UK. It appears that the ‘testing” has been done twice and the geology has proved problematic. This is happening in both the north and south of England.

    Most thinking and responsible people in the UK now want to pursue green alternatives, to protect the environment and planet for future generations of humans and other entities.

  8. Same question could be asked outside the hall, Muriel.

    Suspect the answer may be different.

    Compare and contrast is what people do, Muriel. Not a wise thing to do to encourage that.

    Shame the antis outside were out antied by the vegan demonstration. So much discomfort for so little attention.

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