The Environment Agency (EA) say that they are seeking our comments on the application for Cuadrilla Balcombe Limited for an environmental permit that will enable them to flow test at Lower Stumble in order to appraise the well for the production of oil.
Permit Number: EPR/AB3307XD/V005
Regulated facility type: 1.2 Part A (1) e) (A) 2017 – Storage and handling of crude oil
Regulated facility location: Lower Stumble Hydrocarbon Exploration Site, Off London Road, Balcombe, West Sussex. RH17 6JH
Environment Agency Consultation Guidance
On behalf of our members FFBRA have submitted an objection to Cuadrilla’s application for an environmental permit. FFBRA Response to the Environmental permit consultation RH17 6JH, EPR/AB3307XD/V005submitted by Cuadrilla Balcombe Ltd on 4th June 2018
Please also object in your own words online today by visiting the EA Website
We have prepared some guidance on how to object below. The closing date for the application is Tuesday 5th June so do not delay in voicing your concern it takes 2 minutes.
The Environment Agency (EA) is seeking our comments on the application by Cuadrilla Balcombe Limited for an environmental permit to flow test at Lower Stumble in order to appraise the well for oil production.
The drill site is below the level of the village, and even the top of the proposed flare (which will burn off any gases that come up with the oil) will be below the village, allowing toxic emissions to blow into our homes along the prevailing wind. The Lower Stumble site is in an Area of Outstanding Natural Beauty.
There is a water course within 30 metres that feeds into the River Ouse, and there is an abstraction point further down feeding into the Ardingly Reservoir. The oil well has been drilled in an area with many geological faults, like much of the High Weald. If it leaks, or there is a spill, now or in the future, the water supply in the Ardingly Reservoir could be contaminated.
Please contact the EA to state using your own words one or more of the points below, and to ask that they act with proper caution and REJECT Cuadrilla’s application. Objections can be submitted online here until 5th June 2018.
FFBRA is submitting a technical objection on behalf of its members. However, the number of objections will also count so you are encouraged to make your own.
- Waste gas arising from the acid flow testing will be flared using a flare that has not been tested. Cuadrilla state that they are relying on computer simulations instead of empirical testing – however the computer modelling they are relying on is not for the flare they will be using – it is for an entirely different flare! Given that the prevailing wind from the site blows straight towards the village of Balcombe, and that the site is in a valley so that the top of the flare is below the level of the village, surely as a minimum the EA should insist on revised computer modelling, or on surplus gases being compressed and taken from the site.
- The failure to apply the Precautionary Principle in assessing this permit application would be a gross failure of risk management. Risk management without the Precautionary Principle is essentially 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 reservoir that supplies in excess of 65,000 homes in Sussex. The potential reward is alleged to be increased energy security for the UK. However, according to the Paris Climate Accord, this is an energy source that 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?
- Insufficient study has been made of the geology of the site. We know that the well bore drilled by Cuadrilla in 2013 has penetrated the Paddockhurst Park fault. We don’t know if it has also penetrated the Pilstye Farm fault. Nor do we know if the injection of fluids will endanger the Ashdown Beds aquifer. This aquifer is classified as a key optional source by South East Water and is an important part of their contingency strategy in case of drought. What are the risks of oil exploration 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 leaking wells can increase to 30 or 50 per cent. The most susceptible are “deviated” or horizontal wells such as the Balcombe 2z well. There is also an old well drilled in 1986 on the same well pad less than 10 metres from the new well drilled in 2013. This old well has already been perforated and acid tested in two sections in 1986. No study has been made of the present condition of this old well. No information about it is given in Cuadrilla’s site condition report.
- Cuadrilla have stated that the drilling operation would be conventional, in order to obtain permission to conduct exploratory drilling by West Sussex County Council. 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 hydrochloric 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” shale formations have a permeability of between 0.005 and 0.03mD, so are unconventional.
- All the environmental reports Cuadrilla have done are based on the dispersion calculations undertaken by Atkins for the original flare specified in 2013 and more recently by RSK. The applicant now wants to use a different flare but has not done any new dispersion calculations. Furthermore, this particular flare (the only one of its type in the UK) has not been used before. The assessment of the flare’s safety is based on a computer simulation which may be inaccurate because the design and type of the flare has changed since that simulation was done. It is standard scientific and engineering practice to test the predictions of any computer simulation against physical reality -yet this has not been done. The simulation parameter inputs such as the shrouded flare temperature and input stream gas flow rates are at best guesses. The assessment contains no information about the effect of the flare and fugitive gas emissions on human health. At the well at Horse Hill, there were instances of impacts on human and animal health. Balcombe has the same target formation as Horse Hill, and a more precautionary approach should be taken. The assessment makes no mention of the effect on the health of the residents & visitors to the site. This is particularly concerning giving the fact that the top of the flare is below the level of the village and in the direction of the prevailing wind.
- Sulphur dioxide has not been modelled despite the fact that the data from the Balcombe 1 well drilled in 1986 showed a high sulphur content in the oil extracted. FFBRA has obtained the data from the Balcombe-1well report from 1986 showing 1.5% sulphur in the oil, therefore it can be expected that sulphur dioxide will be produced in the flare. Furthermore, the most recent well report obtained by FFBRA for the 2013 drilling by Cuadrilla shows that the oil in the well is saturated with ‘solution gas’. The gas flow rate and composition are not known and this safety concern must be taken into consideration.
- Constant monitoring of the efficiency of the flare is absolutely vital. This operation is manual (i.e. a man is tasked with watching it). 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 the village. 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, particularly 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. Houses in Rocks Lane are below the well site and are vulnerable to any heavy gases, such as sulphur dioxide, that may be produced.
- 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. Again, the Precautionary Principle should be applied.
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