1. They are injecting fluid into the Bowland Shale and increasing hydraulic pressure “up to the point where the rock would begin to fracture
“9. Does Rathlin accept that the mini fall-off test is also known in the industry as a “mini frac”?
This test is referred to by a number of different names/acronyms. Rathlin is simply testing the formation integrity. ‘Frac’ or ‘mini-frac’ are terms that appear to be used interchangeably by some organisations without clear definition. This is Rathlin’s description of the mini fall off test: The well will be pressured up to the point where the rock would begin to fracture and then will be shut in to monitor the pressure fall off.”
Official Statement, question 9. – Rathlin Energy, 3rd March 2014
2. This is known in the industry as a mini-frack
2. Although they don’t have permission for High Volume Hydraulic Fracturing, the Environment Agency Permits describe a mini fall off test, also known as a mini-frack.
see (1) above, and:
“The DFIT is also known as a FET (Fluid Efficiency Test), MFO (Mini Fall-off) or Minifrac test.”
Pre-frac Injection Fall-off Tests (DFIT) in Ultra Low Permeability Formations – Halliburton, Feb 2012; retrieved August 2014.
3. and will, “help determine whether the formation is capable of being hydraulically fractured”
3. The mini-fracks are being conducted on the Bowland Shale at a depth of ~3000m.
“18.104.22.168 Mini Fall-Off Test within Upper Visean/Lower Namurian
A mini fall-off test is a short duration formation test designed to gather reservoir engineering data (characteristics and properties of the reservoir rock formation). The test is carried out to establish the pressure at which injection of fluid occurs into the formation and analyses how the pressure permeates through the formation over a given period of time (usually 14 days). For clarity, the intention of the mini fall-off test is not to fracture the formation but to establish if and at what pressure the formation becomes permeable. The information gathered during the mini fall-off test will help determine whether the formation is capable of being hydraulically fractured. Hydraulic fracturing is not being considered as part of the application which this plan supports.
The mini fall-off test is being performed … at a depth of 2,677m.
The wellbore will be perforated to provide a flow-path to the formation. The wellbore above the perforated interval will then be sealed using a retrievable packer. Water weighted with non- hazardous Potassium Chloride (KCI) will then be pumped into the wellbore until injection occurs. Fluid is pumped for 5 – 10 minutes, during which 5m3 to 10m3 of fluid is injected. When pumping is complete, the residual pressure within the tubing is shut in and monitored for 14 days to analyse how the residual pressure permeates through the formation.”
EA Permit Application, 03 EPRA – Crawberry Hill – Non Technical Summary, p12
4. Rathlin said in March, “it was “prudent” to test the shale as well [as the conventional reservoirs]”.
“It said its main aims were to test two “conventional” reservoirs– ones that would not require fracking – but that it was “prudent” to test the shale as well.”
Rathlin plans shale tests in northern England – Telegraph, 3rd March 2014
5. They already have the licence from DECC for exclusive access in this area (Petroleum Exploration and Development Licence 183)
Interactive map of all Licence Areas, Planning Permissions and wells – Frack Off
Oil and gas: petroleum licensing guidance – Department of Energy & Climate Change, Dec 2012
6. The regulators rely on the industry self reporting, don’t have the resources to monitor or properly investigate incidents, and rarely visit the sites.
For example, after an operational incident at the West Newton well site on 12th August, serious enough to require expensive well intervention equipment to be brought to site, the Health and Safety Executive (HSE) told a member of Frack Free East Yorkshire:
“The HSE are seeking verification and monitoring the issue, but there is no one from the HSE present on site. They are relying on Rathlin’s duty to keep them informed. They have to provide a weekly report, however out of courtesy Rathlin informed the HSE 2 days ago”
The Environment Agency were unaware of the incident.
7. The Environment Agency has never visited Crawberry Hill …
8. … and is struggling from, “massive job cuts”.
Massive job cuts at the Environment Agency – Independent, 28th Oct 2013
9. Planners haven’t visited West Newton well site since before it was drilled.
“Site visits took place to both sites by the Case Officer Mrs Shirley Ross when the planning applications were being processed by the Council. This is standard practice on all applications and allows the case officer to familiarise themselves with the proposed site and wider surroundings.
Mrs Ross has undertaken site visits to Crawberry Hill on 15 April, 2013 with representatives from the Council’s Environmental Protection and Highway Control team to look at the drilling in operation.
In terms of West Newton Mrs Ross visited the site when the planning application was originally submitted to the Council.”
email from East Riding of Yorkshire Council, 14th August 2014
10. The traffic management plans for both sites have been ignored by Rathlin and Humberside Police.
There should be no convoys, with at least 10 minutes between vehicles. On 2nd July 65 vehicles went to the West Newton well site in massive convoys.
Report by BBC Look North
The route agreed with local residents has been ignored. For example, vehicles have been ignoring the No Right Turn sign when exiting Crawberry Hill well site.
11. Evidence of potential groundwater contamination was ignored by East Riding Council, the Environment Agency, the farmers involved and Birdseye, who bought the potentially affected pea crop.
A tank at Crawberry Hill has been leaking liquid on to the neighbouring field.
Pictures on the Frack Free East Yorkshire > Incidents page (29th May – leaky tank, spills onto fields, Crawberry Hill).
The field (and the land of the wellsite) is owned by farmer Ellerington. The field is being used to grow peas contracted to Birds Eye (revealed in the legal documents for the eviction of Crawberry castle).
Birds Eye were notified of the leak and potential contamination on 6th August. No acknowledgement or response has been received as of 15th August.
In a statement to the High Court of Justice Chancery Division dated 21st July 2014 Mr Ellerington stated:
“Birdseye may also reject the pea crop if there is any overspillage from the Crawberry Hill Wellsite ditches and/or damage to the crop as a result of crop erosions associated with any spillage.” (Claim no HC14E02820 Exhibit “PJE1 Para. 13)
12. “Regulation of the industry in the UK is currently inadequate … Confidence in the practice is undermined by a series of disingenuous claims made by both the Government and industry.”
Shale gas and fracking: examining the evidence – Scientists for Global Responsibility and the Chartered Institute of Environmental Health, July 2014
13. One pro-fracking petroleum engineer says, “we’re going to have unregulated fracking … so you shouldn’t be doing it at all … it’s dangerous for the people of Yorkshire”.
“We’re in the situation in the UK where we’re going to have unregulated fracking… so you shouldn’t be doing it at all… It’s a completely weird and absurd situation- the industry is less pro fracking than the government… so it’s dangerous; it’s dangerous for the people of Yorkshire”
Mike Hill, Oil & Gas Engineer interviewed on BBC Inside Out.
“In an Inside Out energy special, Danni Hewson investigates claims by an industry expert that unregulated fracking could soon be a reality all over Yorkshire and Lincolnshire”
Inside Out Yorkshire and Lincolnshire – BBC One
14. Rathlin: “For the sake of the peace of mind of the community … We feel it necessary to emphasise the short term and temporary nature of our [exploratory planning] application.”
“For the sake of the peace of mind of the community, as the time of the meeting of the Planning committee approaches, we feel we must clarify some aspects of our proposal.
The proposal is for a temporary exploration drilling operation at Crawberry Hill. We feel it
necessary to emphasise the short term and temporary nature of our application. From the data we have acquired, we believe that our site could lead us to discover either oil or gas but we do not know what, if anything will be found. History would suggest that we have perhaps a 20% chance of being successful. We are well aware that any work beyond the specific scope of this application will be subject to a new and detailed planning permission”
THE PROPOSED EXPLORATION WELL AT CRAWBERRY HILL – Rathlin Energy, 8th January 2012
15. They had already signed contracts with the right to lease the land for 50 years, if they find viable reserves.
Revealed in the legal documents for the eviction of Crawberry castle, which included the lease between farmer Ellerington and Rathlin Energy (UK) Ltd.