Dear Environment Agency,
I have a few questions with regard to environmental regulations for the unconventional well stimuation technique of acidisation.
I understand acid washes have been used for a long time to clean corrosive wells and prepare for drilling. I also understand that the process of acidisation has been used for many years to stimulate well flow.
Although some of the principles remains the same, additives are different and the science of how to extract oil improves and yet the science of how it impacts our environment and human health is unknown and doesn’t move as rapidly.
I can not find any regulation in place for the current proposed unconventional method of stimulating deep, horizontal wells which is completely different from an “acid wash”. When I recently
asked DECC similar question about acidisation , officials responded with regulations about fracking fluids.
What is your definition of acid wash?
What is your definition of acidisation?
What kind of chemicals are used in acidisation?
Have you conducted any studies on subsurface release mechanisms including acid wormhole pathways in the rock formation leading to aquifers, fault pathways leading to aquifers, deteriorated abandoned wells leaking into the subsurface, and the failure of production or disposal wells?
What distinguishes an acid wash from matrix acidisation?
What distinguishes an acid wash from acid fracturing with regard to regulation?
What distinguishes flow back fluids from deep well stimulation by acidisation from hydraulic fracturing flowback?
Can I correctly assume that waste fluids from deep well acid stimulation and fracking fluids are regulated in the same way?
How is waste water from matrix acidisation and/or acid fracturing classified?
A few industry reports show that the pH of returning waste is mainly between 0 and 3 for the “first few hours". It is unknown how much of the chemicals returns to the surface for acidizing, but recent data by operators show that the volume of recovered fluids collected after matrix acidisation is 50%- 60% (this would be contrary to what we read about waste water in your directives)
Can this be stored in a reinjection well on site?
Is flowback fluid from deep well acidisation tested for chemicals, pH, toxicity before being reinjected?
Are operators required to list how many times a well has been stimulated by acidisation?
Do you study the fate and transport of the chemicals, their transformations, synergistic and cumulative effects, as well as routes of exposure?
What is the EA's definition of acid wash with regard to the standard waste management plan?
What is the EA;s definition of deep well acidisation (matrix and fracturing) with regard to the standard waste management plan?
Would waste water from deep well stimulation by acidisation require a bespoke permit?
What is your definition of conventional vs. unconventional well stimulation techniques?
Many thanks for answering these important questions.
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