A recent consultation by the EA seeks to allow oil companies to pay a standard fee in order to undertake onshore oil and gas activities without seeking individual permission for specific sites. ttps://consult.environment-agency.gov.uk/portal/ho/ep/src/newrules/oilandgas?pointId=1419248829504#section-1419248829504 Excellent Independent article: http://www.independent.co.uk/news/uk/politics/government-trying-to-fasttrack-fracking-without-public-consent-10314634.html Hydrofluoric acid, one of the most dangerous substances known, is listed as an allowable acid with which to dissolve rock formations (acidisation). This same acid has the potential to kill a human from a large splash and causes permanent lung damage if inhaled. http://www.bt.cdc.gov/agent/hydrofluoricacid/basics/facts.asp It is our belief that the implications of putting this incredibly dangerous acid into our geology have not been fully considered. Although workers and local populations in America are becoming increasingly aware of the risks. http://www.takepart.com/article/2013/09/02/acid-california-fracking-acidizing-monterey-shale A cloud of nebulised Hydrochloric acid from an Exxon Mobil gas flare near the village of Wittorf in North Germany is said to have harmed residents and vegetation, in April of last year. Inhabitants of the local village reported a cloud of what looked like steam and 'terrible smells' around the Söhlingen Z5 well. People even a few km away experienced breathing difficulties, coughing, headaches, red and streaming eyes, inflammation and bleeding pores, burning skin and general malaise. Some were treated in hospital. Exxon Mobil admitted they had flared off the gas 'for technical reasons'. This was just with the use of hydrochloric acid, (also given the go ahead in this consultation) hydrofluoric acid is many times more dangerous. Wells have been known to blow-out or suffer from venting or gas migration, barrier or integrity failure. If a well containing hydrofluoric acid was to blow out what would the consequences be? In America the steel workers union (USW) are campaigning to have its usage stopped. "If released in the atmosphere, HF rapidly forms dense vapor clouds that hover near land and can travel great distances. Like other powerful acids, HF can cause deep severe burns and damage the eyes, skin, nose, throat and respiratory system. But the fluoride ion is also poisonous. Entering the body through a burn or by the lungs, it can cause internal damage throughout the body. At high enough exposures, HF can kill. '' (Executive Summary vi 'A Risk Too Great' United Steel Workers 2010) http://www.usw.org/workplaces/oil/A-Risk-Too-Great.pdf Hydrofluoric acid will extract the radioactive uranium in the well as well as uranium hexafloride in the returned acid wash. Both lethal substances. How will they be dealt with? We know a great number of cancerous toxins enter the air through flaring, what are the implications of this for air pollution? We are concerned that little is known about this process and both MPs and the population are unaware of the dangers associated with it. Where is the HSE's input into this? Where is the training for operators and transporters to deal with this? Dealing with accidents takes highly specialised techniques and substances, fatalities have occurred due to a lack of the appropriate protocol when dealing with victims. http://ehs.unc.edu/environmental/docs/hydrofluoricacid.pdf p.5 Have the local emergency services got the necessary experience in dealing with hydrofluoric acid? Could they deal with a large scale spillage? Who will put this training in place? A huge spill was caused in Korea with terrible consequences, as a result of workers cutting corners. http://www.rsc.org/chemistryworld/2012/11/hydrofluoric-acid-gumi-korea-leak-hube How can we be sure these chemicals are stored appropriately and securely from terrorism or other threats?This has the potential to see tankers carrying this deadly substance travelling up and down our English country lanes and also to make our work force obliged to deal with it. The consultation to object to this dangerous relaxation of individual permits issued by the Environment Agency only runs until Monday 15th June, so there is just a week left for people to lodge their objections. However, in the past they have continued to accept responses that have come in after this date. ttps://consult.environment-agency.gov.uk/portal/ho/ep/src/newrules/oilandgas?pointId=1419248829504#section-1419248829504 Hydrofluoric acid apart, is it right that companies should be able to buy a 'catch-all permit', following which regulatory checks seem to be largely done by the industry? Indeed the EA state "we believe the proposed introduction of standard rules for onshore oil and gas exploration will have a positive impact on business. If operators can meet the requirements of standard rules they do not have to apply for a bespoke permit, thereby saving them time and money." (Standard Rules for the Environmental Permitting Regulations - Consultation No.11, Summary iii) It would appear that regulations are already being eroded to make way for business. The concerns of ecology and local inhabitants are most definitely secondary. Given that we are constantly re-assured that regulations are 'strict' in this country, why, within the space of a year are we seeing a proposed watering down of the regulatory environment, alongside a regime which will be allowing companies carte-blanche to use extremely dangerous substances, whilst largely self-monitoring? We are horrified at the potential for disaster associated with such practices in the UK. One only has to investigate Cuadrilla's actions at Preese Hall and in Balcombe (described as 'grotesque' and 'lamentable' at the hustings we attended by Soames,) to see the potential for things going wrong. Regulations should not been slimmed down so lightly and so easily when the stakes are potentially so high. We urge the government to stop this standard permit authorisation. http://drillordrop.com/2015/04/26/frack-in-lancashire-but-not-in-sussex-says-conservatives-nicholas-soames/ https://consult.environment-agency.gov.uk/portal/ho/ep/src/newrules/oilandgas?pointId=1419248829504#section-1419248829504 Please try and respond anyway you are able! Please see this website for any updates or response ideas... http://www.frackfreebalcombe.co.uk/ Useful Information See HF mentioned at the EA consultation site under Waste Management Plan downloads. p.8 "Acid wash In the drilling and construction of any borehole the drilling process can cause a certain level of formation blinding. This blinding results in a reduction in the level of the natural porosity of the rock formation near to the well bore and is referred to as skin damage. To repair this formation blinding and restore the natural porosity of the formation a low pressure acid wash may be applied. 9 Extractive Waste Management Plan, standard rules permit for oil and water based drilling fluids, acid wash and leak off test. In sandstone formations the treatment will be composed of a 15% hydrochloric acid (HCl) preflush, a main treating fluid (HCl-Hydrofluoric acid (HF) mixtures) and an over flush. In carbonate reservoirs, HCl is the only acid that will be used. In both case the acids will be neutralised by their interaction with the rock formation and form mineral salts, water and carbon dioxide which will be reverse circulated out of the formation for recovery at surface. Between 5m 3 to 15m 3 of HCI may be pumped into the format". This doesn't take into account the problems of 'pockets' of stale or unneutralised acid which can still exist and travel through natural cracks in the rock. Acid facts http://www.bt.cdc.gov/agent/hydrofluoricacid/basics/facts.asp Paper by the United Steel Workers in America: "The Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) regulate HF as highly toxic. EPA requires companies using or storing highly toxic chemicals to gauge how far a worst case release might travel and how many people might be in harm’s way. For HF releases from U.S. refineries, the range is three to 25 miles, depending mostly on the amount stored. " http://www.usw.org/workplaces/oil/A-Risk-Too-Great.pdf Large hydrofluoric acid spill accident: http://www.rsc.org/chemistryworld/2012/11/hydrofluoric-acid-gumi-korea-leak-hube German gas cloud: Press release April 17th 2014 Frack Free Residents Association: http://www.ndr.de/nachrichten/niedersachsen/lueneburg_heide_unterelbe/Saeureregen-auf-Soehlinger-Erdgasfeld%2cgiftwolke101.htm http://www.ndr.de/regional/niedersachsen/heide/giftwolke101.html http://www.radiobremen.de/gesellschaft/themen/regen170.html Oil and Gas company risking local inhabitants health: http://drillordrop.com/2015/02/05/investigation-what-went-wrong-at-west-newton/ Similarly dangerous acids to HF are already being trucked at great risk. See this quote from a report by the Natural Pure Water Association: '"The hexafluorosilicic acid used to fluoridate drinking water has corrosivity potential of hydrofluoric acid which is the most corrosive and one of the most toxic substances known.''The hexafluorosilicic acid is shipped to the water treatment plants in specially lined tanks, containing 4,000 – 5,000 gallons. The shipments are carried by lorries along busy motorways, through densely populated areas and small villages throughout England." "If there were to be a motorway accident involving a hexafluorosilicic acid spill, most hospitals and emergency crews (firemen) may not know what to do, or be ill prepared to cope with the situation. For instance, if the wrong chemicals were used to neutralise the acid, the consequences could be devastating in a densely populated area or busy motorway. If a major roadway accident happened in a small village, much of the village would have to be razed and carried off to a hazardous waste landfill, and the top two feet of soil around the spill would also have to be carted off to a hazardous waste landfill. There is also the potential of well water contamination. If it is raining, then they have an environmental mess on their hands." See website below: http://www.npwa.org.uk/accidents-happen/