Comments on the November 2016 report “A Health Impact of Unconventional Oil and Gas in Scotland” by Health Protection Scotland (HPS)
Summary: The HPS report downplays the dangers of radiation and radioactive contamination from UOG. It does this by selective use of the available facts and data, by pointing to weak epidemiological evidence and by incorrectly inferring that absence of evidence of health effects means such effects do not exist.
- The Scottish Government has requested comments by May 31 2017, on the report “A Health Impact of Unconventional Oil and Gas in Scotland” by Health Protection Scotland (HPS).
- Radiation, radioactive residues and radioactive gases are important matters which must be addressed in any examination of the health impacts of unconventional oil and gas extraction (UOG). Indeed, of all the toxic substances involved in UOG (including chemical toxins, biocides etc.), radioactive materials are arguably the most important. This is because chemical toxins and biocides are mostly restricted to the initial stages of UOG exploration and drilling, whereas radiation, radioactive gases, and radioactive contaminations are produced throughout the lifetime of any proposed extraction. In addition, the actual toxicities involved are greater with the radioactive species released than with chemicals, and the concentrations of radioactive substances are in most cases greater than with chemicals. Perhaps most relevant is the fact that the concentrations of radioactive sludges and scales in surface UOG machinery increase as time goes by as more oil and gas is brought to the surface.
- Unfortunately, the HPS report gives little attention to radioactivity matters and almost none to radiation. The limited attention it does give is unsatisfactory for several reasons as follows.
- Nomenclature. The HPS section on radioactivity gets off on the wrong foot by referring to UOG’s radioactive residues and gases as NORM and TENORM. These seemingly innocuous acronyms stand for ‘naturally occurring radioactive materials’ and ‘technologically enhanced naturally occurring radioactive materials’. They are jargon phrases introduced by and used in the nuclear industry.
- A lay person could be forgiven for thinking that because such materials occur in nature, they are of little concern. But in fact they are extremely toxic and when they are brought to the surface even in moderate concentrations they are dangerous to health. Even at low concentrations they are of concern as there is no safe limit for radiation exposures.
- The reason is that these materials contain, inter alia, radon (Rn-222) and radium (Ra-226). Here is what the standard college textbook “Radiochemistry and Nuclear Chemistry” by Choppin et al (Butterworth –Heinemann Ltd Oxford) states on page 108:“Since Ra and Rn are among the most radiotoxic substances existing, causing bone and lung cancer at relatively low concentrations, special attention must be devoted to their appearance in nature.”
The HPS could have used this quote in their report to Ministers to give them an indication of the serious dangers of these nuclides when they are brought to the surface.
- Undue reliance on epidemiology. For its benign conclusions, the HPS report relies extensively on selected epidemiology studies which, by and large, show limited health effects: even these studies are hedged with qualifications and uncertainties. However as pointed out by Professor Finkel in her critique of HPS’ initial 2015 report, epidemiology studies are often a poor guide to the existence of health effects. (A1) This is especially the case in epi studies of health effects in US fracking regions where few people live. Are these studies which are fulsomely cited by the HPS a relevant guide for the densely populated areas of central Scotland?
- The 2016 HPS report frequently points to epidemiology studies which find no health effects or none which are statistically significant. But, as also pointed out by Professor Finkel, absence of evidence in a health study does NOT mean there are no effects. It merely means the study was unable to find any effects. This is a different matter altogether as there can be many reasons for the lack of case numbers. As stated by Alton and Brand in their famous dictum “absence of evidence does not provide evidence of absence”. (Altman DG, Bland JM (1995) Absence of evidence is not evidence of absence. BMJ. 19; 311(7003): pp 485) If the fictional detectives in the current popular BBC TV series “Line of Duty” can use this dictum repeatedly, as they do, then perhaps HPS should use it as well.
- North Sea Oil and Gas Experience: The HPS report could have used the > 40 years’ experience of Scotland’s North Sea oil and gas extraction. Because of their high exposures to radiation and radioactive residues, pipefitters, welders, roughnecks, etc are routinely classified as “radiation workers” for the purposes of health and safety legislation. Most of these workers wear radiation monitoring badges.
- The reason is that when oil slurries and gases come to the surface they are usually highly contaminated with the radioactive daughters of U-238 and to a lesser extent of U-235. These include radon-222, radium-226 and the extremely dangerous polonium isotope Po-210, the radioactive poison used to kill the Russian dissident Alexander Litvinenko in 2006. They also include the relatively long-lived lead Pb 210 which accumulates in pipes, pumps, and tanks etc and which is a main source of the radiation exposures to oil and gas workers. For example, according to a recent US EPA report on fracking dangers pipework can contain very high concentrations of radioactive lead – up to several MBq per kg. ie millions of becquerels per kg. (A2)
- Although the radiation from these radioactive sludges and scales is partly attenuated by steel pipes, there is another problem: radon-222 which is a radioactive gas. Large quantities of radon are often brought to the surface with oil and methane in process waters, and this excess radon can be inhaled by workers. With UOG on land this would apply to nearby local inhabitants as well.
- Failure to use PHE Report on Fracking: In 2014, Public Health England extensively examined these matters in its report “Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive Pollutants as a Result of Shale Gas Extraction”. (A3)
- Although the HPS mentions the PHE report in passing, it fails to state or address its findings. Unlike the HPS report, the PHE report does not give fracking a clean bill of health. For example, it states (on page 24) “a number of shale gas extraction activities that may impact surface and groundwater and hence have the potential to impact upon drinking water quality:
- Production and storage of fracking fluid and flowback water on site and the possibility of spills from stored ingredients or mixtures which may percolate to subsurface aquifers or may enter surface water courses.
- Well blow out during well completion resulting in contamination of surface waters and also possible impacts on ground water.
- Use of fracking fluids and possible contamination of aquifers during injection and flow back if well integrity is not maintained.
- Release of volatiles during fracking and the possibility of methane and other gases reaching aquifers through poor well integrity and/or through fissures in the strata.
- Treatment and disposal of wastewaters during transportation off-site or improper waste treatment prior to discharge, which may result in possible contamination of surface waters.
- Water resource and acquisition since large volumes are required for borehole drilling and hydraulic fracturing (not being considered in this evaluation).”
- On radon, the PHE report states:“If the natural gas delivery point were to be close to the extraction point with a short transit time, radon present in the natural gas would have little time to decay … there is therefore the potential for radon gas to be present in natural gas extracted from UK shale.”
- It also added eight detailed recommendations as regards any future fracking activities. In particular, it recommended (page 33) that “Baseline environmental monitoring is needed to facilitate the assessment of the impact of shale gas extraction on the environment and public health. There should also be consideration of the development of emission inventories as part of the regulatory regime.”
- In sum, the PHE report, unlike the HPS report, properly addresses the many concerns re possible health effects from proposed UOG activities. At the very least, the HPS report should have commented upon the above findings in the PHE report.
- Failure to use Evidence to the 2014 Public Inquiry at Airth, Stirlingshire on proposed Coal Bed Methane extraction: The Inquiry report had not been completed when the Scottish Government announced its UOG moratorium in January 2015, and the Inquiry proceedings are now suspended. However all the evidence submitted to the Inquiry is publicly available on the DPEA case website (PPA-240-2032). (A4)
- The HPS could have examined this evidence and learned a great deal about the health effects of coal bed methane (CBM) extraction which is similar in some respects to fracking. On radiation and radioactivity for example, it would have learned that, under the then Dart Energy CBM proposals near Airth, about 6 GBq of radioactive residues (mostly from slurries and pipe scales) would have been smeared over the Forth river mudflats opposite Kincardine on Forth each year. This is a very large amount of radioactivity.
- Conclusion: It is concluded that the HPS report fails to properly review the health impacts of UOG activities as regards exposures to radiation and radioactive residues. The HPS report downplays the dangers of radiation and radioactive contamination from UOG, by selective use of the available facts and data, by pointing to weak epidemiological evidence and by incorrectly inferring that absence of evidence of health effects means such effects do not exist.
A1 Professor Finkel’s critique of HPS’ initial 2015 report – http://www.hps.scot.nhs.uk/resourcedocument.aspx?resourceid=3104
A2 US EPA report on fracking dangers – https://www.epa.gov/radiation/tenorm-oil-and-gas-production-wastes
A3 Public Health England, “Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive Pollutants as a Result of Shale Gas Extraction” –https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/329744/PHE-CRCE-002_for_website_protected.pdf
A4 DPEA case website –http://www.dpea.scotland.gov.uk/CaseDetails.aspx?id=94326&T=0