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Some springs on Ikaria, Greece, carry
high levels
of natural radioactivity - but that does not mean
the
radiation is good for you!
Photo: Eleni Ikanou via Flickr. |
A new scientific paper presents the radiation produced
by fracking as 'natural' and harmless. But it's based on sketchy data,
hyperbolic statistics and questionable assumptions, writes Paul Mobbs.
Is it an attempt to stifle an essential public debate?
As the facts about unconventional gas
emerge around the globe the UK Government and the on-shore oil and gas
industry have been pulling-down the shutters on their grand project.
Increasingly reports are "being seen to be written rather than written
to be seen".
For example, last week Public Health England launched the
final version of their report
on shale gas and health - on the same day that the Jimmy Saville
inquiry results were reported. That pretty much ensured there would be
no room in the schedules for any critical analysis of it.
As Government and industry have retreated into their ideological comfort zone,
avoiding public debate on these issues, their defence of unconventional oil and gas policy has become increasingly tenuous.
Criminal scientific negligence
In the face of the evidence now available, they are acting in blind
ignorance of the facts we can established from other nations where
unconventional oil and gas are being exploited on a large scale. In my
view, that indifference to the evidence is such that it could be
considered
criminally negligent.
The most recent addition to the Government's Pantheon of
misinformation emerged last week. With little fanfare, Durham University
issued a press release to publicise a new research paper from the
'ReFINE' project - a.k.a.
Researching Fracking IN Europe, a joint academic, Government and industry project to research the impacts of unconventional oil and gas.
Its title: 'Research finds fracking would increase water radioactivity but would not pose a threat to public health'.
'Within the natural range'
I was immediately suspicious since recent research
has found the opposite,
so I downloaded the paper. They were in such a hurry to get it into the
public domain they hadn't even waited for the journal, who had just
accepted it, to typeset it for publication. The
PDF file was the raw copy which the journal's peer reviewers had just approved.
And what did the paper say? Nothing.
Or rather, nothing which could be readily verified as accurate.
Let's begin (where else?) 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."
'Natural' does not mean 'healthy'
Now what do the mean by
"natural groundwaters"?
They don't mean the local groundwater springs of Lancashire. They're
quoting levels of radioactivity found in a very few 'radioactive
springs'. For example: the spas of
Andalusia in Spain; or the historic hot springs on the Greek island of Ikaria, where workers in the spas can
receive radiation exposures which wouldn't be allowed in the nuclear industry.
Such 'naturally' toxic environments are rare; and highly radioactive
springs are also the rare exception, not the rule. They occur in a few
locations, mostly in geological subduction zones - such as in the
Southern Mediterranean.
That's the problem with the word 'natural'. From naturally toxic
soils, to volcanic caves with acidic atmospheres which dissolve your
lungs, the world contains many 'natural' wonders which are quite harmful
to humans.
There's even a geological strata in Gabon which is so rich in uranium
that when, millions of years ago, groundwater flowed through the rock
it underwent
natural nuclear fission. A fact which the nuclear industry played upon during the 1980s to try and greenwash nuclear power as a 'natural' technology.
The Durham paper uses these exceptions to justify the rule. In
reality, most of the groundwater springs around the world produce
perfectly drinkable water, low in radioactivity and harmful dissolved
minerals. This fact, and the impact of the produced water from fracked
wells, was alluded to in the Durham paper:
"The total activity for Bowland flowback fluid is ~2.5 MBq/yr,
this compared to ~0.021 MBq/yr in surface waters, a difference of 2
orders of magnitude [or 100 times greater]. This highlights a
potentially large risk if surface waters were to become contaminated
with flowback fluid."
Too many statistics, too few data
We must also question the data they used as the basis of their
calculations for the Bowland shale - and the method used to calculate
radiation doses.
Their figures are based on just one site which the Environment Agency monitored - at
Preese Hall
in Lancashire. That's a questionable use of data since it assumes this
one site is representative of the entire Bowland shale - and hence the
whole of Britain.
It is a highly unlikely scenario given the innate geological
variability of shale, and given the potential impacts upon the
environment and human health it is a highly irresponsible approach.
In any case the Environment Agency's sampling of the well was pretty
poor. The monitoring data shows eight sample results spread over a
period of three months - which qualitatively tells us little about the
statistical distribution of pollutants produced by Bowland shale wells
over their gas-producing lifetime.
To be statistically rigorous in characterising a 'Bowland shale
radioactive fingerprint' we'd need a few thousand samples from a few
hundred wells, with a wide geographical spread - and a similar exercise
in every other gas producing area to characterise their footprints too.
Therefore when this paper assumes a statistical distribution of
pollution in order to carry out it's calculations, it's doing so on a
highly tenuous set of assumption about the nature of the Bowland shale.
A leap of faith
It is from this poor statistical base they make a gigantic leap - to
calculate the radiation exposure of the public from flowback water. And
what did they deduce?
"In no scenario was the 1% exceedence exposure greater than 1mSv - the allowable annual exposure allowed for in the UK."
The exposure limit in the UK is not 1 milli-Sievert (mSv) per year. That's the whole body annual dose from
ALL man-made sources. For regulatory purposes the maximum dose permitted from a
SINGLE source is 0.5mSv per year.
More importantly, any source which gives a dose greater than 0.02mSv
per year (which gives greater than a 1 in a million chance of cancer)
has to be investigated; and, if required by law, issued with a permit
which will require certain actions to minimise its impacts upon health
and the environment.
That's the big backroom debate in Whitehall and in the Environment
Agency's HQ at the moment. And it's a debate which is arguably one sided
given that their departing Chairman,
Lord Smith, thinks that fracking is safe,
even in national parks.
Deregulating nuclear safety?
The Government wants to deregulate - but international agreements on
radiological protection require the opposite. Given the level of
radioactivity in the discharges, the Environment Agency must regulate
every fracking pad as a single radioactive discharge. That creates a lot
of form-filling and monitoring problems for the shale gas industry.
As a result, bit by bit, the Government are
trying to dismantle our environmental laws in order to allow unconventional oil and gas to go ahead.
Trouble is they can't be discriminatory. If they were to relax the
law for on-shore oil and gas, then the nuclear industry could argue that
they too should be released from these regulatory burdens.
Given the current regulatory restrictions, the Durham paper makes 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."
But don't people drink water?
Now, what is it that you do with water? Before writing this article I asked a few people what they did with water and the first thing they said was,
"drink it".
That's not the case in the Durham paper.
The paper sets out a method for calculating radiation doses which
doesn't properly evaluate the radiation dose to an affected group, nor
the most exposed individual - which is the regulatory approach taken in
Europe and much of the developed world.
They should have considered both the external dose from daily water
use, but also the more significant issue of water consumption. This
produces a far greater impact upon health due to the action of
'internal emitters'.
From their method, it would appear that only the lesser 'external
dose' has been considered, giving a false result for the impact of these
discharges upon health.
Another statistical slight of hand
Nor does the paper state the source of one of the critical values
(called 'k') which converts the level of radioactivity consumed into a
whole body radiation dose. Therefore we can't independently verify the
results presented in the paper.
Finally, they perform a statistical slight of hand which reduces the
impacts upon dose even further - calculating the total flowback water
production from a certain number of wells based upon their tenuously
assumed distribution of pollutants. A randomly generated sample of these
'probabilistic' figures then forms the input to their dose calculations.
To calculate the impact of contaminated water ingestion is straightforward, using the standard assessment procedure set by the
International Committee for Radiological Protection (ICRP):
- Take the annual amount of water consumed per year (around 730
litres/year, although you would adjust this figure to examine the
impact upon more sensitive groups - such as children).
- Multiply the consumption figure by the levels of the different radioactive elements in the water (for example, by averaging the four samples from the Environment Agency's monitoring of Preese Hall).
- Then for each radioactive element, multiply each figure by the relevant 'Ingestion dose coefficient for members of the public' set in Council Directive 96/29/EURATOM (which is also dependant upon the age of those exposed - the figures for which are published in the Official Journal of the European Community).
- Finally, add those numbers together to produce the total annual dose.
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.
An attempt to stifle a very necessary debate
The difference between these figures is not unexpected. This issue of
contention is that the calculations behind the Durham figure neglect
the impacts of ingesting radiation.
As a result the public can't independently know that these results
are accurate; but perhaps that's the point? Looking with a sceptical
eye, what I see in this paper is an attempt to nullify the debate over
the radiological footprint of shale gas.
We know from
recent US research that, on river beds downstream of the discharge from flowback water treatment plants,
"the
level of radioactivity found in sediments at one brine-treatment
discharge site exceeded the management regulations in the US for a
licensed radioactive waste disposal facility."
Another
recent research paper, which examined the pit lagoons associated with well drilling and flowback, found that,
"total beta radiation ... found in this study exceeded regulatory guideline values by more than 800 percent".
Given what we know of the impacts of the industry elsewhere, the
assumptions in this paper do not correlate to the reality of how
unconventional oil and gas is likely to be extracted in Britain.
Nor does it properly assess the radiological impact in accordance with the process which would be applied by the
Environment Agency as part permitting. Nor by the
Drinking Water Inspectorate if flowback water should ever end up in public water supplies.
Playing down serious impacts
That this paper passed the peer review process should also raise
concerns about the level of scrutiny to which such studies are
subjected.
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.
Paul Mobbs is an independent environmental consultant, investigator, author and lecturer. He runs the Free Range Activism website.
A fully referenced version of this article can be found at
www.fraw.org.uk/mei/musings/2014/20140626-frackings_radioactive_footprint.html.
