Environment Agency Consultation Guidance

The Environment Agency (EA) say they are “minded to grant” Europa’s application to drill at Leith Hill, including the use of a 15% acid solution. This would be a huge mistake. The intended drill site is above a principal aquifer which feeds into Pipp Brook, local springs and the water supply for homes in Leatherhead, Dorking and surrounding villages, and is in a highly faulted area, like much of the UK. If the well leaks, either immediately or in the future, the aquifer could be irreparably contaminated.

Please contact the EA to state using your own words one or more of the points below, and to demand that they act with proper caution and REJECT Europa’s application. Objections can be submitted online here until 29th March 2018.

David Smythe, Emeritus Professor of Geophysics, University of Glasgow is submitting a technical objection on behalf of A Voice For Leith Hill. However the number of objections will also count so you are encouraged to make your own and add that you support Professor Smythe’s submission, if you do. See also our JustGiving crowdfunding page.

The failure to apply the precautionary principle in assessing this permit application is a gross failure of risk management. Risk management without the precautionary principle is essentially simple gambling. That might arguably be acceptable in certain scenarios where the downside impact is low and the potential reward is high. In this instance however, the exact converse is true. The downside impact is the long-term contamination of the aquifer that supplies 70,000 homes across Dorking and Leatherhead. The potential reward is alleged to be increased energy security for the UK, however this is an energy source that according to the Paris Climate Accord we already have five times more of than we can ever safely burn if we are to avoid catastrophic climate change. What security is there in an energy source we can’t use? Surely any sane argument for energy security would be based on renewables which could serve us safely for many decades to come?
Europa’s financial position left them 12 months ago with ‘Cash at Bank’ of £1.4m and an accumulated deficit of £16.6m. Who ends up paying for the clean up if Europa Oil and Gas contaminates our water? What is the extent and terms of their public liability and professional indemnity insurance? If the company ceases trading are their insurance policies immediately invalidated?
Envireau Water’s work at Markwell’s Wood has already been comprehensively discredited by independent hydrologists, following which that site is now subject to an enforcement order that it be restored to its natural state. Why is their analysis at Leith Hill still being given credence, especially given the obvious conflict of interest created by them being paid by the drilling operator? Their risk assessment is based on an overly simplistic site model: e.g. it doesn’t deal with the connection between the Pipp Brook and the aquifer, the effect of near surface faults on groundwater flow or the effect of seasonal and annual water table level variations on groundwater flow. What are the risks in drilling through the heavily faulted geology that runs under watercourses which end up in our water resources? Contamination is known to travel up faults into an aquifer.
Industry studies show that five to seven per cent of all new oil and gas wells leak. As wells age, the percentage of leakers can increase to 30 or 50 per cent. The most susceptible remain “deviated” or horizontal wells like the one being proposed here. SES Water objected to the drill plans on the basis that “the proposed exploratory well will penetrate the lower greensand aquifer in relatively close proximity to our Dorking abstraction source. We are concerned that, in the event of a leak or a spill, the proposed mitigation measures will not guarantee the aquifer’s protection.” SES Water have no vested political or economic interests in this proposal. Why were the objections of their unbiased, independent experts not heeded?
Europa were granted conditional permission to conduct exploratory drilling by the planning inspectorate on the basis that the drilling operation would be conventional. As a result, the permit wording should preclude the use of all stimulation techniques, not just hydraulic stimulation. The use of acids to stimulate oil flow is not a conventional technique. Although 7.5% acid washes are used in conventional wells, use of higher concentrations of Hydrochoric acid at the high ambient temperatures of the target formation and at high pressure is not a bore washing technique, it is the unconventional technique known as acidisation and is akin to hydraulic fracturing. N.B. Any reservoir with a permeability of less than 0.1 mD is by scientific definition unconventional and so will require stimulation. The Kimmeridge Clay “limestone” formations have a permeability of between 0.005 and 0.03mD.
Europa are claiming that “all of the dilute acid solution will return to the surface once it has reacted”. However, at Broadford Bridge in West Sussex, operator UKOG (also the largest financial interest in Europa’s project) have just had to announce serious problems with their oil retrieval - the liquid they are retrieving contains a large quantity of acid which remained underground from historic acid washes. This casts serious doubt on claims that all of the solution will be retrieved here.
Hundreds of chemicals including a 15% hydrochloric acid solution will be used at the site. Why is a Groundwater Activity Permit is not required? The EA claim to have assessed the chemicals in the products that Europa want to use, and consider them not to present a risk that would make a Groundwater Activity Permit necessary. There is an inventory of hundreds of chemicals listed in the waste management plan. Is there peer reviewed evidence that each of these chemicals is safe to use in this type of drilling operation? If not the precautionary principle should be applied - our drinking water should not be put at risk.
What will happen to the highly saline produced water and backwash from this operation. This typically also includes reaction products of injection chemicals and the formation rocks, and substances released or leached out from the formation, including salts, heavy metals and Naturally Occurring Radioactive Materials (NORMS). What volumes are currently forecast? There are no licensed facilities for handling this type of waste in southern England. Where will it go? How can an ecologically rich Area of Outstanding Natural Beauty be considered appropriate for the safe management and transport of naturally occurring radioactive materials (NORMs)?
Waste gas arising from testing will be flared using a shrouded flare. The assessment of the flare’s safety is based on a computer simulation which may be inaccurate because new research shows methane and ethane emissions associated with oil & gas extraction are higher than previously thought. This is particularly the case for the Bakken Shale in the US, which has been compared by the industry in the UK to the Weald. At UKOG’s site at Horse Hill near Horley, when flow testing was carried out, residents complained of headaches & respiratory problems. The assessment contains no information about the effect of the flare and fugitive gas emissions on human health. Given the reports from Horse Hill, and the information about fugitive emissions from the Bakken Shale and its similarity to the target formation, a more precautionary approach should be taken. The assessment makes no mention of the protest camp which is directly opposite the site and the effect on the health of the residents & visitors there. Special consideration is given to the effect Nitrogen Oxide emissions on a nearby Site of Special Scientific Interest, where ‘there is a potential exceedance of the 24 hour critical level for NOx (Nitrogen Oxide)’ - why should the same consideration not be extended to the entire local area, which equally contains older native woodland (e.g. the row of old oak trees which starts near the entrance). The proposed drill site and surrounding area is a haven for protected fauna species such as hazel dormice, nightjar, cuckoo, tree sparrow and song thrush.
Constant monitoring of the efficiency of the flare is absolutely vital. If the flare efficiency falls below 95% then the flare will start to emit serious amounts of toxins, which will be transported on the prevailing wind towards Dorking. These include:
- Sulphur dioxide (SO2): At room temperature, sulphur dioxide is a non-flammable, colourless gas with a very strong, pungent odour and is heavier than air. Inhalation is the major route of exposure to sulphur dioxide. Most exposures are due to air pollution, and this has both short-term and chronic health consequences for people with lung disease. Inhaled sulphur dioxide readily reacts with the moisture of mucous membranes to form sulphurous acid (H2SO3), which is a severe irritant. People with asthma can experience increased airway resistance with sulphur dioxide concentrations of less than 125micrograms/m3 when exercising.
- Polyaromatic hydrocarbons: Polyaromatic hydrocarbons are by-products arising from incomplete combustion of organic matter that are frequently released into our environment. They are produced in flares. Many polyaromatic hydrocarbons are strong carcinogens and have been linked to increased incidences of various types of cancer in humans for which there is no known safe threshold concentration or exposure time.
- Particulate matter (PM): Nano-sized soot particles are generated in the flare which are detrimental to public health. Further air dispersion calculations of particulate matter (PM) generation are necessary, and the results should be added to emissions predicted from generators and traffic.
- Dioxins Can the operator please provide information on expected dioxin levels in the flare gas? Dioxins are formed when incinerating chlorine-containing organic substances. Dioxins are very toxic and known human carcinogens and endocrine disruptors. A study conducted in the Netherlands reports the presence of dioxins in flared landfill gas, biogas and chlorine containing industrial gas. (National Institute of Public Health and Environmental Protection & Netherlands Organization for Applied Scientific Research, Report 770501018, Emissions of Dioxins in the Netherlands, February 1994). The dioxin levels of the flare gas should be monitored continuously, and contingency plans should be put in place should dioxins be detected in the flare gas.
- Volatile organic and inorganic chemicals and synergy of emissions. Workers and residents near to the flare will be exposed to benzene, ethylbenzene, xylene, toluene, pyrene, benzanthracene, anthracene, NOx, sulphur dioxide, carbon monoxide, radon, soot and many other combustion emissions. The risk of simultaneous exposure to such a cocktail of chemicals is completely unknown.