Following information provided by Climate Justice Taranaki (CJT) and others and the reporter’s own research, Radio NZ put together a series of reports on the disposal of drilling and fracking waste on landfarms in Taranaki (See links below). Shortly after the broadcast, TRC put out five statements on its website, criticizing the reports.
CJT has these points to raise:
– CJT took note of TRC’s assertion that only “one landfarm had been consented to accept fracturing fluids”. Three points worth noting are:
i) TRC never required consents specific to fracking wastes until July 2011 so there might be no clear record of how and where fracking wastes were “historically” disposed of prior to that date. There is at least one record, on BTW’s Brown Road landfarm, where “fracture water” has been landfarmed in July 2010.
ii) TRC said the landfarm with the consent to dispose of fracking waste is now closed although its “consent remains in force while comprehensive soil testing is carried out…” This consent was granted in July 2011 and is valid till June 2027. Why is such a long consent duration required here when landfarms in Alberta (fracking wastes excluded) are allowed to operate for only 5 years by which time soil conditions are expected to return to acceptable standards for other landuse?
iii) Why is there no stock withdrawal period in the consent? e.g. The 2010-2011 report on the Brown Road landfarm concluded that hydrocarbons for recent disposals did not meet consent limits. Yet in August 2010, the inspector reported, “regrowth for the recent application area looked well established, and bulls were grazing the pasture.” Is it safe for dry stock to be grazing on operating landfarms?
– CJT has always been careful in distinguishing drilling wastes from fracking wastes because of the different chemicals involved. However, landfarming of drilling wastes (without fracking wastes) in itself calls for serious concerns. As explained in detail in our Nov 2013 submission to the Parliamentary Commissioner for the Environment, TRC’s consent conditions for landfarming (not specific to fracking wastes) deviate significantly from Alberta guidelines. CJT argues strongly that drilling waste disposal (with or without fracking waste) should not occur on food producing land, whether it is for dairy, dry stock or crops. It’s simply too risky and irresponsible.
– Although TRC, in its document Future directions for the management of oil and gas operations (Nov 2013), recommends deepwell injection for fracking fluids disposal, its Guide to regulating oil and gas exploration and development activities under the RMA (Oct 2013) suggests otherwise: “Disposing of drilling waste and return fluids to land through land farming, if managed effectively, is recognised internationally as presenting a relatively low cost disposal option with low environmental impacts. The use of natural microbial respiration processes to degrade waste presents an environmentally sound and environmentally beneficial disposal option for waste fluids produced by exploration and production activities in the Taranaki region, including hydraulic fracturing and well workover fluids.” (p.128) The Ministry for Environment has included disposal of fracturing fluids to land in its draft guidelines for local governments “Managing environmental effects of petroleum development activities (including hydraulic fracturing)“, Oct 2013 (p.45-51).
– The Alberta Energy Regulator website link TRC provided lists numerous AER guidelines. Directive 050 deals not only with land treatment (or landfarming), but landspray, pump-off, disposal onto forested public lands, mix-bury-cover, sending drilling waste to approved waste management facilities and mobile thermal treatment units, etc… Communications with AER stated clearly that “Frac flowback fluid” is an oilfield waste subject to storage under Directive 055 and management under Directive 058. Land application (as described in 050) is not an authorized disposal option.
– TRC asserted that “All soils must meet consent surrender criteria for all residues before any alternative land use is allowed”. This contradicts with a number of TRC inspectors’ observations, including the above mentioned comment on Brown Road in Aug 2010, and:
i) TRC monitoring (2005-2006) on the Geary landfarm revealed, “Further treatment of hydrocarbons is required” in several areas. Yet the TRC inspector reported in November 2005, “Recent spreading had taken place near the new pits. Stock were grazing the new areas – G32 and G33”
ii) On the C Boyd landfarm near Inglewood, the inspector reported in April 2010, “Cows were grazing one paddock where muds [drilling wastes] had been applied and were working the mud into the soil nicely with their hoof action.”
– A recent review of NZ’s food safety regulations highlighted “a shortage of people with dairy processing and regulatory expertise at every level of the regulatory sector”, a need for improved traceability of dairy products and the lack of government funding on food safety research. Last month’s contamination of 14 Fonterra milk trucks by a trailer carrying drilling wastes mistakenly ended up in a Fonterra cleaning facility should have been a serious alarm call. Yet the 150,000 litres of contaminated milk was simply dumped through the Eltham wastewater treatment plant which is not designed to treat mining waste. To this date, there has been no disclosure of information about the source and content of the contamination and it is unclear what tests were conducted to conclude that milk products were unaffected. Notably it’s not until today’s (18 Dec 2013) news broadcast that the Ministry of Primary Industry came out to say they had recently introduced new requirements for dairy farmers who allow mining wastes to be spread on their farms and step up monitoring of this sector.
– Importantly, there’s been no health study in Taranaki at fine enough scale to determine the health impacts from oil and gas operations on nearby residents (human and animals), through air pollution from flaring and contamination of water and soil. A 2012 study by McKenzie et al. in Garfield County, Colorado, has revealed that residents living less than 1/2 mile from wells are at greater risk for health effects than are residents living farther than 1/2 mile from wells. The Bamberger and Oswald (2012) study conducted across six US states have documented numerous health effects on animals and animal owners. A poignant quote from the authors: “Complete evidence regarding health impacts of gas drilling cannot be obtained due to incomplete testing and disclosure of chemicals, and nondisclosure agreements. Without rigorous scientific studies, the gas drilling boom sweeping the world will remain an uncontrolled health experiment on an enormous scale.”
– CJT reaffirms its call for an immediate, nationwide ban on fracking and disposal of drilling and fracking wastes on all farms. The risks on food safety, animal health and the environment are too great to justify continuation of such practices. Fracking perpetuates the problems of fossil fuels, from exacerbating climate change to generating toxic wastes that cannot be disposed of safety (by landfarming or quake inducing deepwell injection). Instead of furthering fossil fuel extractions and industrial agriculture that rely heavily on fuels and chemicals, NZ government should be promoting sustainable energy and agricultural systems, and transition to a low carbon economy that does not depend on growth.
Radio NZ links:
Taranaki residents concerned by disposal of fracking waste (Interview with Sarah Roberts; Radio NZ 17 Dec 2013, 6:37 am)
Impact of fracking and landfarming questioned (Interview with Gary Bedford and Sarah Roberts, TRC; Radio NZ 17 Dec, 7:09 am)
Canadian authorities dispute Taranaki fracking disposal claims (Interview with Gareth Hughes; Radio NZ 17 Dec, 8:09 am)
Taranaki Council responds to controversial fracking practice (also response from MPI, CJT, Open Country Dairy and farmers; 7:19 am 18 Dec)
Milk on dump farms to be tested (Taranaki Daily News, 19 Dec)
Conundrum for dairy industry in New Zealand’s land of milk and oil (Xin Hua Net, 17 Dec)