The Environment Agency has said it is considering granting a permit for oil exploration at the Bury Hill Wood site, near Leith Hill in Surrey.
But before reaching a final decision, the organisation says it wants to consult the public.
Comments can be submitted online until 15 March 2018 (link). The EA is hosting a drop-in meeting in Dorking on Thursday 1 March 2018.
The consultation concerns a mining waste permit, one of the few consents still needed by Europa Oil and Gas before it can start work at the site, also called Holmwood. The company also needs approval from Surrey County Council for its traffic management plan.
In a statement, Europa’s Chief Executive Office, Hugh Mackay, said:
“We are pleased to have reached this important stage in the environmental permitting process. Whilst we are still in the determination process and a final decision has not been made, it is nonetheless positive that the Environmental Agency is inclined to approve. We look forward to the outcome of the consultation process and will keep shareholders updated.”
An Environment Agency (EA) spokesperson said of the drop-in meeting:
“This is a great opportunity for local people to find out more about the proposed operations at Holmwood and how the Environment Agency would regulate such activities.
“An environmental permit sets out stringent conditions that a site must adhere to. We will not issue an environmental permit for a site if we consider that activities taking place will cause significant pollution to the environment or harm to human health.
“We want to hear from the public and understand people’s views on this application and to raise any concerns before we make any final decisions.”
More than 91,400 people have signed a petition calling on the Environment Agency to reject the permit application related to oil drilling near Leith Hill. The petition also urges the EA to improve water monitoring proposals by to adding additional locations and extending the monitoring period.
What the EA said about Europa’s plans
Europa submitted its permit application in February 2017. The EA asked for extra information in June 2017 and the company submitted details every month between July 2017 and January 2018.
In a document on the decision, issued last week, the EA said it had taken into account “all relevant considerations and legal requirements” and that the permit, currently in draft form, would “ensure that a high level of protection is provided for the environment and human health.”
Acid wash and squeeze
The EA said Europa had initially proposed to carry out an acid wash to clear any formation damage caused during drilling. It would then do an acid squeeze, in which acid would travel up to 14m into the formation and may result in stimulation of oil flow.
The campaign group, Leith Hill Action Group (LHAG) said in its comment on the permit application that Europa proposed to use acid at higher levels that would normally be expected. The group said acid fracking was analogous to hydraulic fracturing and could lead to increased risks of seismic disturbance and pollution of groundwater and water courses.
During the application process, Europa said it intended to clear damage within a 1m radius of the wellbore, the EA said. Pressure used to pump acid into the well would be below that needed to fracture rocks.
The EA said a maximum of 95m3 of hydrochloric acid would be pumped into the formation over a maximum of three acid and squeeze operations in the Portland sandstone, Kimmeridge micrites and Corallian sandstone.
It did not respond to a request from LHAG to confirm whether hydrofluoric acid would be used.
The EA said the chemicals in two proposed products, Protekt15 and Protekt 7, were of a quantity and concentration that was “so small as to obviate any present or future danger of deterioration in the quality of any receiving groundwater”. As a result, it said, no groundwater activity permit was required.
The EA added that a list of proposed chemicals and volumes were published as part of the public consultation, with the exception of propriety chemicals that were excluded for commercial reasons.
LHAG described the financiers of the drilling as technically insolvent”. It said:
“There is a significant risk that the operator may not be able to fulfil the restoration or remediation of the site if the company goes bankrupt prior to an application to surrender the permit.”
The EA responded:
“There is no known reason to consider that the operator will not be financially able to comply with the permit conditions.”
It added that Europa had confirmed that it was not subject to any insolvency procedures.
““The Environment Agency has no reason to suspect that the operator is not a fit and proper person to operate a permit”.
The EA said there were discrepancies between the permit and planning applications in Europa’s proposed underground route of the well. The surface casing in the permit application went to a much shallower depth and the angle of drilling near the surface had also changed.
The company said that by changing the angle of the upper part of the wellbore, it could get across identified faults in the geological sequence but still remain in the Weald Clay and reach target formations.
The EA also said it had questions about the depth of the Weald Clay. This largely impermeable layer is a vital protection for groundwater, the EA said. The decision document said Europa had shown that there should be over 400m depth of Weald Clay to protect groundwater in the Tunbridge Wells Sand formation.
The EA said it had raised questions about Europa’s proposed use of a Bentofix GCL liner to protect soil and groundwater from spills on the site. The manufacturer had recommended the Bentofix NSP 4900. Since the original application, Europa has accepted the manufacturer’s recommendation and guidelines on installation.
Europa proposes to flare any gas in the target formations. LHAG had raised concerns about potentially carcinogenic air pollution from the flare. The EA said Europa’s proposed monitoring was satisfactory to control air quality emissions.
The EA said Europa had estimated that noise from flaring would be less than the 115 decibels. The EA added:
“Where noise limits set under planning conditions cannot be met the operator has committed to reduce the flow rate at the choke manifold, which in turn will reduce the inlet flow rate of hydrocarbon gas to the flare, resulting in a reduction in sound power level and impact at receptors.”
The Bury Hill Wood site is less than 50m from ancient woodland and 600m from a site of special scientific interest.
The EA said nitrogen oxides from the flare could potentially exceed the daily critical level in the adjoining ancient woodland but this would be limited to an area of 10m-20m from the site boundary. It said flaring was for a total of 15 days and the activity was considered low risk. Natural England did not respond to the EA consultation on this point.
There are no emissions limits for point source emissions to air in the draft permit, except for limits on temperature and flare gas feed flow rate. Europa will calculate oxides of nitrogen, carbon monoxide and total volatile organic compounds based on measurements at the wellhead, the EA said.
On other wildlife issues, the EA said:
“We consider that the application will not affect any sites of nature conservation, landscape and heritage, and/or protected species or habitats identified. We have not consulted Natural England on the application. The decision was taken in accordance with our guidance.”
Area of Outstanding Natural Beauty
The site is the Surrey Hills Area of Outstanding Natural Beauty (AONB). Europa argued that there was no viable alternative site for exploring outside the AONB. The EA said:
“based on the areal extent and the temporary nature of the proposed operation that development cannot be considered to have a significant effect on the enjoyment of the special qualities of the Surrey Hills”.
LHAG also raised concerns that drilling would disperse radioactive substances that had remained undisturbed for millions of years. The EA said Europa was applying separately for a radioactive substances permit. No public comments are being sought on this application because it is a standard rules permit.
The drop-in meeting is at Dorking Halls, Reigate Road, Dorking RH4 1SG from 2pm-7.30pm.
Updated 20/2/2018 with quote from Hugh Mackay