Enterprise & Energy Hydraulic Fracturing
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Enterprise & Energy Hydraulic Fracturing Submission to the Parliamentary Commissioner for the Environment 11 October 2012 Dr Jan Wright Parliamentary Commissioner for the Environment PO Box 10-241 WELLINGTON 6143 Dear Dr Wright SUBMISSION TO THE PARLIAMENTARY COMMISSIONER FOR THE ENVIRONMENT’S INVESTIGATION INTO HYDRAULIC FRACTURING IN NEW ZEALAND 1. Introduction 1.1 Todd Energy (Todd) welcomes the opportunity to provide input into your investigation regarding the use of hydraulic fracturing in New Zealand. We hope this investigation will provide the clarity required to properly inform the public on both the merits and perceived risks of hydraulic fracturing in a New Zealand context. 1.2 Todd wants to improve the public discourse on these issues and is strongly committed to assisting in that by providing full transparency about our hydraulic fracturing operations in New Zealand. In that spirit, we have endeavoured to provide a plain language, comprehensive picture of our operations with considerable background detail. We will also make this submission available to the public. 1.3 We reiterate our invitation to you to visit our Taranaki wellsites and observe a hydraulic fracturing operation, and would welcome the opportunity to provide any further information that may be helpful to your investigation. 1.4 There are important differences between types of fracture treatments, target formations, and the depths at which they are performed, and these matters are addressed in considerable detail in the submission as they impact significantly on the level of any possible risks. 1.5 Todd’s hydraulic fracturing operations are in line with international best practice, and have developed and will continue to be refined through a process of continuous improvement. They are safe and have minimal impact on the environment. Todd complies fully with the New Zealand regulatory regime, which we regard as sound and fit for purpose. The information and evidence set out in this submission supports this position. The following are the main points of our submission. 2. Regulatory framework for hydraulic fracturing 2.1 The increased public focus on hydraulic fracturing has already prompted the Taranaki Regional Council (TRC) to review and refine regulation of hydraulic fracturing operations in Taranaki. 2.2 The enhanced regulatory framework including specific resource consents, compliance requirements and public disclosure for hydraulic fracturing activities, together with regulations such as the Hazardous Substances and New Organisms Act 1996 (HSNO), adequately protects the environment and is fit for purpose. 2.3 This view is reinforced by the findings of detailed analyses and studies by the TRC and GNS Science in Taranaki which found no detectable evidence of water or air quality contamination or of seismic events arising from or relating to hydraulic fracturing. 2.4 Industry has also responded to public concerns with moves to provide greater transparency around its operations. This should be strongly encouraged. 2.5 Data disclosure requirements under the resource consents should be restricted to relevant data, but should be regularly reviewed to ensure that they remain fit for purpose and allow for innovation. 2.6 The hydraulic fracturing consent framework implemented by the TRC should be adopted by other councils. 2.7 Should further regulation be proposed for hydraulic fracturing, despite the absence of any evidence of significant environmental damage caused by hydraulic fracturing in New Zealand, it should be risk based, and recognise that depth, well construction methods, the types of fluids and chemicals used, and the volumes of water used have a significant impact on the magnitude of the environmental risk. 3. Environmental risks associated with hydraulic fracturing 3.1 Many of the environmental risks raised as concerns relating to hydraulic fracturing apply to all exploration and production drilling. They are well recognised by the industry and managed through adherence to high quality well construction and best practice in all operations. 3.2 The primary environmental concern raised in relation to hydraulic fracturing is the risk of contaminating shallow freshwater aquifers and surface water with hydrocarbons or fracture fluids. 3.3 Todd uses low volume conventional fracturing, typically in sandstones below 3,000 metres, with multiple layers of overburden and cap rock seal. The risk of contaminating a shallow freshwater aquifer or surface water during such treatments is significantly lower than in high volume water fracturing used in shallow shale gas developments in the United States. 3.4 Todd uses state-of-the-art well construction and fracture monitoring procedures. The risk of fractures extending into aquifers or fluids escaping up between the well and surrounding rock is virtually non-existent. 3.5 A potential environmental risk associated with deep hydraulic fracturing in Taranaki would be accidental surface spillage of chemicals or fracture fluids containing low concentrations of mild contaminants. This is effectively managed through strict adherence to high quality health, safety and environmental management procedures and compliance with HSNO and other regulatory controls for the handling, transport and disposal of chemicals and returned fluids. 3.6 The types of chemicals used for hydraulic fracturing have changed substantially over the last twenty years. Most are environmentally benign and are common in many household products. Fracturing fluids that are 100 percent benign are rapidly coming on market. Fracture fluid composition is fully disclosed in consents and on many company websites. 4. Seismicity 4.1 Downhole micro-seismicity (below 2M on the Richter scale) induced by fracturing, is highly unlikely to be felt at the surface. Slightly higher energy events have been linked with fracturing in some countries, typically related to geothermal projects. 4.2 A GNS study conducted in Taranaki concluded it is unlikely that hydraulic fracturing operations have caused detectable earthquakes. 4.3 Public concern has been expressed about the possibility of hydraulic fracturing operations activating a natural fault. The risk of this occurring in deep gas formations in Taranaki is very slight. 4.4 Part of the normal risk assessment involved in planning hydraulic fracturing includes identifying the presence of any faults from seismic reflection surveying data and avoiding these. 4.5 Avoiding hydraulic fracturing near faults is also good operating practice from the perspective of obtaining a successful fracture treatment result. This is because a fault may act as a ‘thief zone’ for the treatment, thereby compromising the operational objective, and potentially leading to early programme termination. 5. Natural gas as a transition fuel 5.1 Todd supports the move to more sustainable energy sources and has invested in hydro, solar and geothermal assets, and tidal and landfill gas energy developments. 5.2 Nevertheless it is likely that fossil energy sources will continue to play an important role for the foreseeable future. Consumers are not prepared to meet the very large costs that would be necessary to replace the 61 percent of New Zealand’s total energy supply met by non- renewable sources, with renewables. 5.3 Solar, wind and hydro energy are very weather dependent and rely on thermal generation as a back-up. The latter two also leave significant environmental footprints. 5.4 As the cleanest burning fossil fuel, with significantly lower greenhouse gas emissions than coal, natural gas is the obvious, affordable, reliable transitional fuel. 5.6 Tight gas resources are required to secure New Zealand’s long term gas supply, and their production necessitates the use of hydraulic fracturing. Paul Moore Chief Executive Todd Energy This submission has been prepared by Todd Energy to assist the Parliamentary Commissioner for the Environment with her enquiry into hydraulic fracturing. It may not be relied upon by any other person or for any other purpose. While the authors have taken all care to ensure the accuracy of the information in the submission, they accept no responsibility for errors or omissions. Contents Table of Figures ........................................................................................................................ 4 Table of Tables .......................................................................................................................... 5 Foreword ......................................................................................................... 7 Executive Summary ....................................................................................... 9 Chapter 1: Introduction ................................................................................ 23 1.1 Todd Energy ................................................................................................................ 24 1.2 New Zealand oil and gas sector................................................................................. 26 1.3 Basic petroleum geology ........................................................................................... 27 1.4 Petroleum exploration and development ................................................................. 28 1.5 Conventional and unconventional petroleum resources ....................................... 29 1.6 Hydraulic fracturing techniques ................................................................................ 31 Conclusion ..............................................................................................................................