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Submission on Fracking Legislation

category national | environment | news report author Tuesday September 27, 2011 13:09author by PAW - People's Association Watchdog Report this post to the editors

PAW Highlight the Dangers of Fracking to Human Life, Nature and The Environment.

Today sees the release of the People's Association Watchdog's Submission on Fracking to the government, some of the noted points of concern include the use of TOXIC Chemicals used in the process and the important questions of water pollution, air pollution waterway contamination are also highlighted.
One of the main concerns raised in the document is the likely constitutional offences that fracking may endorse.
The People's Association Watchdog have published their findings today and a copy of the submission has been sent to all TDs and relevant parties.

Submission
On
Fracking
By
The People's Association Watchdog
September 27th 2011

https://www.facebook.com/groups/p.a.watchdog/?
id=169549489790263¬if_t=group_activity

We, the members of the People's Association Watchdog (PAW), call upon the government to
BAN FRACKING in Ireland.

The People’s Association Watchdog (PAW) is a group of informed concerned citizens who engage
ourselves in addressing current issues. As citizens of Ireland we are angered at decisions being
taken for short term gain regardless of their inherent destructiveness. It is much more prudent,
responsible and ethical to plan and make decisions based on long term success and ecologically
sustainable ways forward.

We believe that fracking, with or without chemicals, is in direct contravention of existing
environmental and water legislation, is unconstitutional and is a danger to Irish citizens, wildlife,
environment and culture. Until such time as it is proven that fracking will cause no environmental
or social damage that will affect Irish citizens, our children and our children's children the
Precautionary Principle must apply. (Aarhus)

We believe that allowing fracking will place not only our own but also our children’s health and
their inheritance of this country at risk, through contamination of the water supply, the release into
the atmosphere of unknown compounds and destruction of large areas of the countryside.
Furthermore, any financial gains to the country through facilitating this devastating process would
not answer any immediate requirements in reducing this countries financial deficit. Also, should
there eventually be a financial gain; it would take a considerable time to filter through to the
exchequer. The taxation levels currently proposed would provide insignificant returns in terms of
the amounts that are required to balance the country's books and there is in fact no actual guarantee
that there would be any return at all.

In addition, it is obvious that the safety regulations proposed in the Consultation Paper on the High
Level Design of the Petroleum Safety Framework will be neither adequately robust nor adequately
enforced to prevent serious environmental, social and economical damage to the country as a whole
and in particular to the areas where permission for fracking exploration has been facilitated to date
by the State.

Fracking contravenes Article 45.2.ii of the Irish Constitution.
Article 45.2.ii states: That the ownership and control of the material resources of the community
may be so distributed amongst private individuals and the various classes as best to subserve the
common good.

Fracking also contravenes:

• STATUTORY INSTRUMENTS. S.I. No. 272 of 2009, EUROPEAN COMMUNITIES
ENVIRONMENTAL OBJECTIVES (SURFACE WATERS) REGULATIONS. 2009.

• STATUTORY INSTRUMENTS. S.I. No. 9 of 2010 European COMMUNITIES
ENVIRONMENTAL OBJECTIVES (GROUNDWATER) REGULATIONS, 2010.

• European Communities (Environmental Liability) Regulations, 2008.
To date, fracking has been banned in France (1), Quebec in Canada (2), George Washington
National Forest in the U.S. (3), New York in the U.S. (4); also moratoriums have been placed on
fracking in New South Wales in Australia (5), South Africa (6), U.K (7), New Jersey in the U.S.(8),
and Pittsburgh in the U.S. (9).

Within the European Community, legislation is currently under review with respect to hydraulic
fracturing activity, following the controversy surrounding the industry in the U.S. The European
Parliament's Committee on Environment, Public Health and Food Safety has commissioned a
report:

'Impacts of shale gas and shale oil extraction on the environment and on human health' (10).
It would at least be prudent on the part of the current Government to await the results of this report
and the American Environmental Protection Agency (EPA) study into the practice of fracking. The
results of this study will be available in late 2012 (11).

Current Proposed Regulations.

These are detailed in the Consultation Paper on the High Level Design of the Petroleum Safety
Framework CER/11/137 (12) which we believe will lead to a complete lack of regulation and
unsafe practices because of a likely low level of enforcement of its requirements. The Commission
for Energy Regulation (CER) has a responsibility to ensure that safety regulations are consistent and
within best international regulatory practice. In the foreword of this paper, Dermot Nolan (CER
Chairperson) and Garrett Blaney (CER Commissioner) have both signed that it is their intention to
deliver a safe Irish petroleum exploration and extraction industry.

However, by page iii of the executive summary this has been reduced to a mere
vision of a safe Irish petroleum exploration and extraction industry and the role of the CER is
reduced to fostering and encouraging safety in petroleum exploration and extraction activities.
The goals of CER are that petroleum undertakings reduce risks to safety to a level that is ALARP,
which translated means 'as low as practically reasonable'. Whilst there is within this paper a
whole section devoted to how ALARP is to be achieved, there is no clear statement on who sets the
level that is as low as reasonably practical, or who should set these limitations, CER or the
petroleum companies.

We have absolutely no confidence in the safety levels currently set by the petroleum companies
based on the many environmental catastrophes already recorded and even were these set by CER,
we have no confidence in the enforcement of those limitations.

Whilst the reasons are clearly given as to why the intention that the framework should be 'goal
setting' rather than prescriptive in its nature, regulation can not be discretionary. Limitations and
safety measures must be clearly defined and regulated to ensure that operators act in a safe and
responsible manner toward the environment and Irish citizens. At this point this is impossible given
the poor levels of research, knowledge and experience therefore hydrofracking must be banned.
In the introduction to Consultation Paper on the High Level Design of the Petroleum Safety
Framework CER/11/137, it states that CER is responsible for the safety regulation of petroleum
undertakings as covered by the Petroleum (Exploration and Extraction) Safety Act 2010. It further
states that safety is not defined by the Act nor in any other Acts but is taken to mean (section
3.2.2.3) a state of the absence of danger. We believe that hydrofracking in any form will not allow
this state to exist in any normal sense of the word. Fracking presents a high level of danger to the
environment, our citizens and future citizens regardless of how well regulations are enforced or
adhered to.

No Chemical Fracking
To date fracking has never been carried out anywhere in the world without the use of chemicals.
Richard Moorman, Chief Executive of Tamboran, one of several companies who now hold licences
for exploration in this country has stated that no chemicals will be used in the fracking process.
(13) (27)

• Fracking expert Dr Anthony R Ingra ea, a professor of e ff ngineering at Cornell University in
New York, with 30 years experience in rock fracture mechanics, who worked directly for
the world's leading oil and gas completion company stated "It is highly unlikely that there
could be an economically produced shale gas well, of the scale that is commonly being
used in the United States, using only water and sand." (29)
It is widely recognised that fracking releases numerous hazardous materials from shale rock
including methane, heavy metals and high levels of radiation, these having been found in water
returning to the surface following fracking. These are substances which are released from the shale
itself and in addition, thousands of gallons of toxic chemicals will be likely to be used for every
well that is drilled. The area proposed is known to be a high radon area.
There is also the issue of the disposal of the fracking solutions which is posing huge problems in
areas where fracking has been allowed as well as the high incidence of accidents during the
processing. The transportation of fluids is yet another risk which would face Ireland's already
highly challenged water and road systems.
Information currently available to you through the EU can show that highly toxic chemicals are
added to the water/sand mix (15).

• Scientist Dr. Aedin McLoughlin, a resident of Ballinaglera, Co. Leitrim, advised a recent
meeting (16) that she had serious concerns regarding the consequences of fracking, for
water, land and the community. She described as “misinformation” an assertion by
Tamboran that the company will not use chemicals to extract the gas, stating this part of the
process would be subcontracted to other companies. Dr. McLoughlin stated: “I think they
are being very clever saying ‘we’ will not be using chemicals", because Tamboran only carry
out the exploratory stage of the process – but they are not actually stating that the company
who will follow on to produce the gas won’t use these potentially lethal chemicals”.

Water Supply

It is ironic that at the very time the government is going to install water meters to conserve already
scarce water and is also considering using the river Shannon for water supply to Dublin to satisfy
scarcity, it is considering developing an industry which relies on huge supplies of water in its
processes. How will this resource be found? Provision of such large quantities of water to this
industry is likely to hugely impact on already scarce supplies of water for domestic use. (28)The
Lough Allen basin contains a myriad of linked waterways and underground water systems, it also
contains the source of the Shannon River. Tamboran MD Richard Moorman states 'We plan to
utilize between 1 million and 2 million gallons of water per well, sourced only from rainwater and 1
to 4 ground water wells next to the drilling pad (all to be stored onsite in a fresh water pond). We
will utilize the groundwater wells to frequently test the quality of water at the wellsite.' This
amount of water could not be sourced from rainwater, it would be extracted from ground
wells and from the loughs and rivers. (31)

Water Quality

Water quality, whether with or without chemicals, will be affected. In areas where fracking has
taken place, water supplies have been seriously contaminated by the gas produced, rendering the
ground water and the lakes, rivers and streams totally unfit for human or animal use and leading to
the poisoning of all of these water supplies and the subsequent loss of plant and animal life. This
has been demonstrated in many studies by reputable organisations globally and so far not one study
has proven that fracking is not the cause of these disastrous consequences. MD of Tamboran,
Richard Moorman has said 'Ireland’s shales are quite shallow (1.0 to 1.5 km), so do not require the
extensive water requirements of the much deeper US shales' (28) (31)
Responding to years of complaints of water contamination and illnesses from citizens in rural
Wyoming, the EPA investigated the water quality of 39 wells surrounding a small community
besieged by gas drilling. The agency found a wide range of contaminants, including heavy metals
such as lead, arsenic, copper, vanadium, and methane gas in the water. (17)

Waste Water

Waste water is difficult and expensive to treat, one of the already existing reasons that Ireland does
not use ocean water for agriculture and residential applications. If fracking is allowed, millions of
gallons of waste water will be generated. Where fracking has already been allowed, this has led to
issues such as accidental spills, cases of non-containment and road accidents. In particular, the
waste water from fracking has been shown to contain high levels of radium and radon; this would
clearly have devastating effects on both citizens and the environment.There is no infrastructure in
Ireland for treating this toxic/radioactive water, so what will happen to it? The contaminated water
would either be stored on the sites of the well pads or transported in large trucks along the poor
quality roads in the proposed areas. This would be a very high risk operation and likely to lead to
many accidents (29)

Irish Countryside and Tourism industry

Much of the land designated on the Fracking map is in rural Ireland, areas whose economies are
based on long term sustainable industries such as farming, fishing and tourism. These industries will
be devastated by fracking industry.
As a tourist, would you consider visiting a location that has:
Shale Gas Pads placed every 2-4 km (1-2 miles) which may contain up to 16 wells per pad, are
made of flattened concrete and take up an area of 12 acres per pad. (26) There would be one of
these pads roughly every half to 1 mile.

This will render large areas of the countryside, loughs and forestry currently attracting tourists
through its natural beauty, wildlife and flora, destroyed and leave even those areas in-between
totally unattractive and dangerous to both local residents and visitors.
These pads will require an access road suitable for heavy trucks and will have a 60 ft drilling tower
and 4 flowback containers (40ftx40ftx15ft) per well, along with a water pit the size of a soccer
pitch.

There will be machinery of various kinds, including tankers, trucks, pipelines and containers
creating a heavily industrialised zone, causing damage and danger to already restricted country
roads and likely causing pollution with the high risk of accidents.
While drilling is taking place, local residents are likely to be subjected to noise and light pollution
on an unimaginable and intolerable scale.(28)

The areas in Ireland where licences for exploration have been allocated to-date are scenic and
coastal locations which rely totally on agriculture or tourism and other sustainable industries. These
would be severely negatively impacted by fracking.

Gas versus Coal

Although gas burns cleaner than coal and oil, the extraction, processing and transport of natural gas
emits large amounts of methane, a potent greenhouse gas (GHG). Methane has a global warming
potential 21 times greater than carbon dioxide on a 100-year scale, and 72 times greater than carbon
dioxide on a 20-year scale. A recent, ongoing Cornell University analysis suggests that the
footprint of shale gas may be 1.2 to 2.1-fold greater than coal’s on a 20-year timeframe. Recently
the EPA drastically increased estimates of methane leakage from the natural gas industry. The
revised percent figures estimate emissions from unconventional natural gas operations at 9,000
times higher than previous estimates. Yet, due to inadequate data regarding unconventional natural
gas extraction from resources such as shale gas, the EPA maintains that these revised percent figures
likely underestimate the total amounts.

Professor Robert Howarth and colleagues from Cornell University, using EPA estimates of methane
leakage from natural gas operations, put natural gas ahead of coal in terms of GHG emissions. The
EPA recently estimated that fugitive methane from the petroleum and natural gas sector equals the
annual equivalent of 40 million passenger cars. (18)(31)

Dr. Theo Colborn of The Endocrine Disruption Exchange (TEDX) reports that once drilling is
complete, produced water continues to surface for the life of the well for 20 to 30 years. (19)
A 2009 Department of Energy report suggested that between 30 and 70 percent of fracking Fluids
remain underground, however the DOE noted the uncertainty of determining the exact fate of the
fluids: “it is not possible to unequivocally state that 100 percent of the fracturing Fluids have been
recovered or to differentiate flow back water from natural formation water.” (20)

Destruction of Woodland

The proposed areas contain large tracts of Coillte woodland. Is it the case that fracking companies
have already negotiated purchase/use of these lands? It may be significant that Richard Moorman
of Tamboran has stated that they foresee working primarily in wooded areas. (21) (Reference
comment thread on Journal.ie article)

Roads and Other Infrastructure

The roads in the proposed areas are rural and are not constructed to withstand the weight of traffic
currently using them let alone the passage of oil tanker sized trucks. These roads would be severely
damaged and dangers of pollution risks are highly likely due to the obvious likelihood of accidents
and spills of toxic chemicals and waste water.

Will fracking companies be required to upgrade, maintain and repair roads that their trucks use or
will this place a further severe burden on the already overstretched roads budget?

Existing Evidence:

• The N.Y. Dept. of Transportation believes that as much as $222 million in damage to local
roads could occur because of the massive influx of heavy plant traffic necessary to operate
fracking wells. (22)

• One Denton, Texas study determined that for all three phases of a gas well -- drilling,
fracking, and maintenance -- approximately 592 one-way truck trips were required per well.
Some individual trucks weighed as much as 80,000 to 100,000 lbs when fully loaded. (23)
Politicians and People Unite in Their Call for "No Fracking"

• "Tamboran is giving false promises on the basis that they will subcontract the actual
fracking to another company who have not made the no chemical pledge. The process will
kill fish, burn the ground and destroy tourism." - Leitrim County Councillor Gerry Dolan
(IND)

• "What we are facing is outrageous. This area has the richest heritage in Europe and this will
ruin our heritage and tourism potential. (16)

• Mayor of Roscommon Cllr Eugene Murphy (FF) "Although fracking might bring in a once
off €15B to the economy, agriculture brings in €24B every year."

• Independent TD Luke “Ming” Flanagan (IND) "It is illegal to put poison in someone’s tea,
but not to put it in the rivers and seas. Why should we give a multinational [company] a
resource that belongs to Ireland? The people need to stand up and be counted. They might
think that in Leitrim we are poor, and maybe we are – but we are not cheap and we will not
be bought off." (16)

• Leitrim Councillor Martin Kenny (SF) said tax incentives had helped bring a building boom,
but the lesson from that was “a fast quick buck just does not work”. He believed gas firms
had met quarry owners and local trucking firms regarding potential for business. “They
might think that in Leitrim we are poor, and maybe we are – but we are not cheap and we
will not be bought off,” (16)

• Leitrim County Councillor Gerry Dolan said he believed tourism and farming industries
could be “wiped out” if gas exploration companies get the go-ahead. (16)

• Independent TD Luke “Ming” Flanagan, who is opposed to fracking, warned of its impact
on the tourism industry, which in Roscommon and south Leitrim had potential to grow by
€90 million. (16)

• Mayor of Roscommon Cllr Eugene Murphy (FF) noted fracking was banned in a number of
countries and called for “an absolute and total ban” here. (16)

• Under questioning by the councillors, Mr. Moorman did admit that there is no evidence the
process will work, but he said “I am confident it can be done.” (25)

• Cllr. Sinead Guckian said her concern was that “our county will be used as a guinea pig.”
Protesters outside also said they did not want Leitrim to be a “guinea pig” for Tamboran. Mr
Moorman said Tamboran will use sub-contractors for some of the work but they too will not
use any chemicals and will have the same views as Tamboran.(25)

• Leitrim Observer Tuesday 13 September 2011. Dr. McLoughlin, the “rural enabler” for Co.
Leitrim under the EU-funded Peace III programme, which supports reconciliation projects in
the Border area, said the region, known for its natural beauty, would effectively become an
“industrialised zone” comprising a series of shale gas pads every 2km to 4km. Each pad
would have a flattened concrete foundation of 2.5 acres, with eight wells, access roads for
trucks, 60 ft. drilling towers and water pits the size of soccer pitches, she said. (16)
Aside from sand and chemicals, the process of fracking uses phenomenal amounts of water forced
at high pressure (typically 10000 psi) into the wells. This part of the process, even if all else is
proven safe, will be difficult to justify in Ireland - a country with water shortages which with
climate change will likely increase.

An Taisce (National Trust for Ireland)
TAKEN FROM THE EUROPEAN PARLIAMENT SCIENTIFIC STUDY INTO THE
IMPACTS OF SHALE GAS AND SHALE OIL EXTRACTION ON THE ENVIRONMENT
AND ON HUMAN HEALTH 2011
POLICY DEPARTMENT AN ECONOMIC AND SCIENTIFIC POLICY:

Environmental Impact Key Findings:

1. Unavoidable impacts are area consumption due to drilling pads, parking and manoeuvring areas
for trucks, equipment, gas processing and transporting facilities as well as access roads.

2. Major possible impacts are air emissions of pollutants, groundwater contamination due to
uncontrolled gas or fluid flows due to blowouts or spills, leaking fracturing fluid, and uncontrolled
waste water discharge.

3. Fracturing fluids contain hazardous substances, and flow-back in addition contains heavy metals
and radioactive materials from the deposit.

4. Experience from the USA shows that many accidents happen, which can be harmful to the
environment and to human health. The recorded violations of legal requirements amount to about
1-2 percent of all drilling permits. Many of these accidents are due to improper handling or leaking
equipments.

5. Groundwater contamination by methane, in extreme cases leading to explosion of residential
buildings, and potassium chloride leading to salinization of drinking water is reported in the vicinity
of gas wells.

6. The impacts add up as shale formations are developed with a high well density (up to six wells
per km²).
Human Health Concerns:
Because of trade secrets the composition of the additives is not fully disclosed to the public. [Wood
et al 2011]

An analysis of a list of 260 substances provided by New York State leads to the following results:

• 58 of the 260 substances have one or more properties that may give rise to concern.
• 6 are present in list 1 of lists 1-4 of priority substances, which the European Commission has
published for substances requiring immediate attention because of potential effects to man or
the environment: Acrylamide, Benzene, Ethyl, Isopropylbenzene (cumene), Naphthalene,
Tetrasodium Ethylenediaminetetraacetate.
• One substance (Naphthalene bis (1-methylethyl) is currently under investigation as, bio
accumulative and toxic (PBT).
• 2 substances (Naphthalene and Benzene) are present on the first list of 33 priority substances
established under Annex X of the Water Framework Directive (WFD) 2000/60/EC - now
Annex II to the Directive on Priority Substances (Directive 2008/105/EC).
• 17 are classified as being toxic to aquatic organisms (acute and/or chronic).
• 38 are classified as being acute toxins (human health) such as 2-butoxy ethanol.
• 8 substances are classified as known carcinogens such as benzene (GHS classification: Carc.
1A) and acryl amide, ethylene oxide, and various petroleum based solvents containing
aromatic substances (GHS5 classification: Carc. 1B).
• 6 are classified as suspected carcinogens (Carc. 2) such as Hydroxylamine hydrochloride.
• 7 are classified as mutagenic (Muta. 1B) such as benzene and ethylene oxide.
• 5 are classified as having reproductive effects (Repr. 1B, Repr. 2).
• 2-butoxy ethanol (also called ethylene glycol monobutyl ether) is often used as chemical
additive. [Bode 2011], [Wood et al 2011] It is toxic at relatively low levels of exposure. The
half-life of 2-butoxy ethanol in natural surface waters ranges from 7 to 28 days. With an
aerobic biodegradation rate this slow, humans, wildlife and domestic animals could come
into direct contact with 2-butoxy ethanol through ingestion, inhalation, dermal sorption and
the eye, in its liquid or vapour form, as the entrapped water reaches the surface. Aerobic
biodegradation requires oxygen, which means that the deeper 2-butoxy ethanol is injected
into underground layers the longer it will persist. [Colborn 2007].

While the EU legislation may require further consideration with regard to Energy Extraction
directives, there are currently 6 clear directives in place that can be considered and will be
examined by PAW and other interested parties to ensure the best interests of the environment and
the population in general, these are:

Mining Waste Directive: Natura 2000
Ambient Air Quality: Ground Water Directive
BAT Note (BRAF): Habitats & Bird Directives
Seveso II: Ambient Air Strategy
EIA Directive: Water Framework Directive
REACH: Environmental Liability

Furthermore, for EU-legislation on waste alone, 36 directives, regulations, recommendations and
the like are listed. In total, this collection probably comprises hundreds of documents relevant for
environmental aspects.

In order to assess the current EU regulatory framework focussing on hydraulic fracturing, the lists
of up to 12 directives are not exhaustive, while the collection of hundreds of regulatory documents
is too encyclopaedic. Nevertheless, some of the lists were especially composed to give an overview
of the EU regulatory framework relevant for the exploitation of shale gas.

Relevant EU-Directives

Below are just some of the EU Directives that PAW and others will be examining in depth at each
and every stage of the proposal to inflict fracking on the population and environment of Ireland.

1. 2000/60/EC
Directive establishing a framework for Community action in the field of water policy (Water
framework directive).

2. 1980/68/EEC
Directive on the protection of groundwater against pollution caused by certain dangerous substances
(repealed by 2000/60/EC with effect from 22 December 2013).

3. 2006/118/EC
Directive on the protection of groundwater against pollution and deterioration.

4. 1986/280/EEC
Council Directive on limit values and quality objectives for discharges of certain dangerous
substances included in List I of the Annex to Directive 76/464/EEC.

5. 2006/11/EC
Directive on pollution caused by certain dangerous substances discharged into the aquatic
environment of the Community (Codified version).

6. 1998/83/EC
Directive on the quality of water intended for human consumption.
Relevant EU Directives on the Protection of the Environment
Directive:

7. 2010/75/EU
Directive on industrial emissions (integrated pollution prevention and control).
IPPC-Directive

8. 2008/1/EC
Directive concerning integrated pollution prevention and control (codified version)
Decision
2000/479/EC
Decision on the implementation of a European pollutant emission register (EPER) according to
Article 15 of Council Directive 96/61/EC concerning integrated pollution prevention and control
(IPPC). Annex A1: List of pollutants to be reported if threshold value is exceeded.

9. 1985/337/EEC
Environmental Impact Assessment Directive. EIA Directive

10. 2003/35/EC
Directive providing for public participation in respect of the drawing up of certain plans and
programmes relating to the environment and amending with regard to public participation and
access to justice Council Directives 85/337/EEC and 96/61/EC.

11. 2001/42/EC
Directive on the assessment of the effects of certain plans and programmes on the environment
Strategic Environmental Assessment (SEA).

12. 2004/35/EC
Directive on environmental liability with regard to the prevention and remedying of environmental
damage.

13. 1992/43/EEC
Directive on the conservation of natural habitats and of wild fauna and flora. Natura 2000

14. 1979/409/EEC Directive on the conservation of wild birds.

15. 1996/62/EC Directive on ambient air quality assessment and management.
Relevant EU Directives on safety at work
Directive

16. 1989/391/EEC
Directive on the introduction of measures to encourage improvements in the safety and health of
workers at work.

17. 1992/91/EEC
Directive concerning the minimum requirements for improving the safety and health protection of
workers in the mineral-extracting industries through drilling.

18. 1992/104/EEC
Directive on the minimum requirements for improving the safety and health protection of workers
in surface and underground mineral-extracting industries.

19. 2004/37/EC
Directive on the protection of workers from the risks related to exposure to carcinogens or
mutagens at work (codified version).

20. 1991/322/EEC
Directive on establishing indicative limit values by implementing Council Directive 80/1107/EEC
on the protection of workers from the risks related to exposure to chemical, physical and biological
agents at work.

21. 1993/67/EEC
Directive laying down the principles for assessment of risks to man and the environment of
substances notified in accordance with Council Directive 67/548/EEC.

22. 1996/94/EC
Directive establishing a second list of indicative limit values in implementation of Council
Directive 80/1107/EEC on the protection of workers from the risks related to exposure to chemical,
physical and biological agents at work.

23. 1980/1107/EEC
Council Directive of 27 November 1980 on the protection of workers from the risks related to
exposure to chemical, physical and biological agents at work.

24. 2003/10/EC
Directive on the minimum health and safety requirements regarding the exposure of workers to the
risks arising from physical agents (noise).
Relevant Directive on Radiation Protection
Directive

25. 1996/29/Euratom
Directive laying down basic safety standards for the protection of the health of workers and the
general public against the dangers arising from ionizing radiation. N.O.R.M. (Naturally Occurring
Radioactive Material) Directive
Relevant EU Directives on Waste
Directive

26. 2006/21/EC
Directive on the management of waste from extractive industries and amending Directive
2004/35/EC - Mining Waste Directive
Commission Decision
2009/359/EC
Decision completing the definition of inert waste in implementation of Article 22(1)(f) of Directive
2006/21/EC concerning the management of waste from extractive industries.

27. 2006/12/EC
Directive on waste - Waste Framework Directive.

28. 1999/31/EC Directive on the landfill of waste.
Commission Decision
2000/532/EC
Decision establishing a list of (hazardous) wastes pursuant of several Directives (replacing Decision
94/3/EC)
Commission Decision
2009/360/EC
Decision completing the technical requirements for waste characterisation laid down by Directive
2006/21/EC on the management of waste from extractive industries.
Commission Decision
2009/337/EC
Decision on the definition of the criteria for the classification of waste facilities in accordance with
Annex III of Directive 2006/21/EC concerning the management of waste from extractive industries.

29. Decision
2002/1600/EC
Decision laying down the Sixth Community Environment Action Programme
(Article 6 (2)(b): “…developing further measures to help prevent the major accident hazards with
special regard to those arising from pipelines, mining, marine transport of hazardous substances and
developing measures on mining waste…”)
Relevant EU Directives on Chemicals and associated accidents
Directive

30. Regulation 1907/2006
Regulation concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH), establishing a European Chemicals Agency - ECE/TRANS/215 8
United Nations Economic Commission for Europe (ECE): European Agreement Concerning the
International Carriage of Dangerous Goods by Road. ADR applicable as from 1 January 2011.

31. 1996/82/EC
Directive on the control of major-accident hazards involving dangerous substances - Seveso II
Directive.

32. 2003/105/EC
Directive amending Council Directive 96/82/EC (Seveso II Directive) on the control of majoraccident
hazards involving dangerous substances (this Directive is currently under review). [The
most important extensions of the scope of that Directive are to cover risks arising from storage and
processing activities in mining, from pyrotechnic and explosive substances and from the storage of
ammonium nitrate and ammonium nitrate based fertilizers.]

33. 1991/689/EEC Directive on hazardous waste.

34. 1967/548/EEC
Directive on the approximation of laws, regulations and administrative provisions relating to the
classification, packaging and labelling of dangerous substances.

35. 1999/45/EC
Directive concerning the approximation of the laws, regulations and administrative provisions
relating to the classification, packaging and labelling of dangerous preparations.

36. 1998/8/EC
Directive concerning the placing of biocidal products on the market.

References
1. http://www.connexionfrance.com/Shale-gas-drilling-ban-F...ring-
12722-view-article.html
2. http://www2.canada.com/calgaryherald/news/calgarybusine...f4d1-
4b86-99e3-4d0b91cbe46b
3. http://coalseamgasnews.org/?p=1310
4. http://www.huffingtonpost.com/2011/02/09/hydraulic-frac....html
5. http://www.bloomberg.com/news/2011-07-21/new-south-wale...gfor-
coal-seam-gas.html
6. http://www.reuters.com/article/2011/04/21/us-safrica-fr...10421
7. http://www.upi.com/Science_News/2011/06/03/UK-fracking-.../UPI-
21541307144514/#ixzz1RJosOVkh
8. http://www.njspotlight.com/stories/11/0310/2151/
9. http://www.cbsnews.com/stories/2010/11/16/national/main...ml%29
10.
http://www.europarl.europa.eu/document/activities/cont/...715AT
T24183EN.pdf
11. http://www.propublica.org/article/epa-launches-national...uring
12. www.cer.ie/GetAttachment.aspx?id=82296014-ea4d-406f-89b3
13. http://www.irishtimes.com/newspaper/ireland/2011/0906/1....html
14.
15. www.anglocelt.ie/news/roundup/articles/2011/08/10/4005993-tamborans-claims-of-chemicalfree-
frack-fluid-challenged-by-expert/
16. The Irish Times - Saturday, September 3, 2011 - Gas fracking would 'split community')
17. http://www.irishtimes.com/newspaper/ireland/2011/0906/1....html
18. www.epa.gov/region8/superfund/wy/pavillion/PavillionWyomingFactSheet.pdf
19. www.desmogblog.com/natural-gas-industry-rhetoric-versus-reality
20. www.endocrinedisruption.com/chemicals.introduction.php
21. www.propublica.org/article/new-gas-wells-leave-more-chemicals-in-ground-hydraulicfracturing
22.www.yourlawyer.com/blog/leaked-document-warns-of-heavy-truck-traffic- damage-linked-tofracking.
23. www.marcellus-shale.us/road_damage.htm
24.
www.leitrimobserver.ie/news/hostile_atmosphere_at_tamboran_information_meeting_1_3058744
25.
www.leitrimobserver.ie/news/leitrim_to_be_guinea_pig_for_zero_chemical_fracking_1_3042738
26.
http://www.gazschiste.files.wordpress.com/2011/02/jonah...w=800
27.http://www.independent.ie/national-news/gas-firm-denies...rand-
pollution-2882530.html
28.http://www.thejournal.ie/readme/column-want-to-boost-th...gas/?
utm_source=shortlink
29.http://www.youtube.com/watch?v=mSWmXpEkEPg
30.http://www.feasta.org/2011/03/16/shale-gas-bonanza-or-hype/
31.http://www.caseyresearch.com/cdd/fracking-controversy

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PDF Document PAW Submission on Fracking in Ireland 0.17 Mb

author by Ruaidhripublication date Tue Sep 27, 2011 13:23Report this post to the editors

Also... Richard Moorman admitted at the public meeting in Carrick that while no chemicals will be used in the extraction process, chemicals WILL be used in the drilling process. He also point blank refused to identify what those chemicals were. He's being disingenuous and playing with words when he says there will be no chemicals. There will. The man is a liar and is purposely misleading the public.

author by Fergalpublication date Thu Oct 06, 2011 00:34Report this post to the editors

Congratulations on the work, this is great material, very comprehensive and uses good arguments. There's a real need to get more general info out there too for people though so we know what we're dealing with...

author by Lucy Bingham McAndrewpublication date Sat Oct 08, 2011 10:35Report this post to the editors

http://www.guardian.co.uk/environment/2011/oct/07/keyst...aring

Tar sands are up there with fracking in terms of negative environmental impact. I'm surprised there's not more information on indymedia about this - or have I missed something?

 
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