Environmental Regulation of Hydraulic Fracturing in Queensland

摘要

Since the late 1990s, coalbed methane (CBM) has grown to be a significant part of the Queensland economy, building alongside the world-scale coal export operations. Environmental regulation in Queensland, over the same period, has become highly integrated with petroleum activities following a unified mineral rights/land tenure and environmental permitting process. Development of environmental regulation of CBM evolved with the sector as industry-specific issues became evident. Following the announcement around 2008 of a number of multi-billion dollar LNG export projects with upwards of 40,000 wells, attention by interest groups and the public at large, gave rise to increased scrutiny by regulators of the scope of prevailing rules. Environmental regulation in Australia is largely state-based with nationally agreed guidelines adopted for various media (air quality, receiving water, drinking water etc). In respect to the environmental aspects of CBM development, a National Framework has been recently agreed to, identifying performance principles including hydraulic fracturing, however the details will be developed and regulated by the states. In respect to the application of hydraulic fracturing, the CBM sector have indicated a likelihood of fracturing up to 40% of wells and the development of the extensive shale gas / tight gas resources (horizontal completions with 100% fracturing) is moving into exploratory stages. Thus the State can expect a very significant rise in application of the technology. To date, because of the relatively few operators in the energy sector, permitting has been project based rather than rule based, resulting in older approvals having conditions inconsistent with modern expectations. The State Government has moved to amend this position by developing more performance focused codes that will have retrospective application in respect to new hydraulic fracturing programs. It has also moved toward greater emphasis on compliance activities. In respect to environmental regulation of hydraulic fracturing the State proposes a single comprehensive code encompassing the use of the technique across all energy sources and fluid systems: conventional oil and gas; unconventional oil and gas; and geothermal. The approach developed for environmental risk mitigation follows a series of pre-event disclosure requirements, engineering constraints, environmental protection measures, product accreditation, monitoring and post-event reporting. Fundamental to the approach is a comprehensive risk assessment considering a wide range of issues at local and regional scales. Environmental considerations include air, land and water impacts, ecological parameters, geological issues, noise, and waste. Performance matters include well integrity, water management and product specifications. Disclosure of products is required under Petroleum and Gas legislation but this code requires product accreditation under an international standard encompassing contaminant concentration limits, human toxicology and eco-toxicology. Evidence supporting code development includes both actual consideration of the environmental issues in Queensland and detailed review of hydraulic fracturing studies being undertaken or recently completed across the world. A detailed legislative review was completed considering rules from 54 jurisdictions (including Australia, United States, Canada, UK and Scotland, France and South Africa) across 58 identified regulatory matters. The following general principles and practices have been proposed to underpin the revised code in order to minimize the likelihood of adverse impacts from hydraulic fracturing: 1.? Detailed understanding of the local stratigraphy including aquifers, faults, linear features, hydraulic conductivity, porosity, seismic risk and groundwater dependent assets; 2.? Detailed engineering understanding of the impacts of applied stresses including aquifer drawdown, on connectivity to aquifers above and belo