Measures to protect the environment during proposed work at the Balcombe oil site in West Sussex are “inadequate, incomplete and misleading”, villagers have complained.
The site operator, Angus Energy, is seeking planning permission to flow oil from the well during three years of tests.
A risk assessment, submitted by the company, concluded that any effects on groundwater quality were likely to be negligible.
But in objections published online today, Balcombe Parish Council and the community group, Frack Free Balcombe Residents’ Association said the risk assessment “distorted facts”, was “oversimplified” and made “subjective statements”.
Both said the risk assessment was invalid and could not be relied on.
Balcombe Parish Council said:
“The application should be refused on the grounds that the hydrological risk assessment is inadequate, incomplete and misleading.”
Frack Free Balcombe Residents’ Association (FFBRA) said:
“Angus are cutting corners and trying to get permission to flow the well without adequate protection to the environment or baseline tests. They have not provided proper engineering designs.”
Angus Energy’s managing director, George Lucan, said in a statement:
“We are confident that our Hydrogeological Risk Assessment fully and professionally addresses the proposed works and look forward to the review of our application”
The risk assessment was submitted in January 2020, three months after most of the other application documents.
It was required by the Environment Agency, which initially objected to the application, saying Angus Energy had not a fully justified its assessment of risks to the environment.
A decision on the application due this month has been delayed and is now not expected before 24 March 2020.
“Distorted facts” on well integrity
Balcombe Parish Council in its objection criticised what the risk assessment said about the integrity of the Balcombe 2 well, drilled by the former site operator, Cuadrilla in 2013.
The risk assessment referred to a cement bond log, a test of how well the cement around the well bonded to the casing and the surrounding rocks.
The cement bond log supported the conclusion that risks to groundwater from failed well integrity were considered to be “very low”, the risk assessment said.
But on this issue, the parish council said the risks assessment “distorts facts and cannot be relied upon”.
The only cement bond log carried out on the Balcombe 2 well rated the cementing as mostly “moderate to poor”. In the section at depths of 600ft-708ft it said there was “poor casing to cement bond and cement to formation”. This section corresponds with a section of the Ashdown Beds aquifer.
A review of the Angus risk assessment for FFBRA concluded this meant there could be “possible breaches in the cement seal” and an increased risk to groundwater quality if there was a leak in the well column. It added that the potential use of hydrochloric acid in the well might exacerbate this weakness.
Balcombe Parish Council called for tests to confirm there were no breaches to well construction and for remediation if necessary.
“Production disguised as testing”
Angus Energy’s application seeks consent to test the flow of the well. But this will produce oil that Angus Energy can sell.
A previous planning application in 2017 proposed just a seven-day flow test.
Balcombe Parish Council said:
“By describing the work as ‘flow testing’ for three years, the applicant is avoiding applying for a production licence.
“Regulations for a production licence are much stricter than those for flow testing. Angus Energy is trying to avoid applying for a production licence by disguising this application as a ‘flow test’.
“This should not be permitted.”
Frack Free Balcombe Residents’ Association said Balcombe was an important site for Angus Energy:
“Angus would like to say they have permission to produce oil (and revenue) to their investors. Hence their application is to produce oil over a three- year period which they have clumsily disguised as ‘well testing’.
“Two applications in one”
The Angus Energy application proposes two separate operations.
The first stage, lasting seven days, seeks to remove water from the well and establish whether oil is present. Stage 2 is to flow the well for three years.
The company has proposed to remove all equipment between the two stages and install safety and environmental protection measures before stage 2 begins. These include a flare to burn off waste gases, a perimeter containment bund, impermeable membrane and emergency shut down system.
Balcombe Parish Council said the two stages should be treated as separate planning applications.
It said the risks in stage 1 had been underestimated. It called for the membrane and bund proposed for stage 2 to be provided in stage 1.
It also criticised the lack of detailed plans for the containment system and bunded area in stage 2.
FFBRA suggested, in its objection, that the application had been shaped by the deal to transfer operatorship from Cuadrilla to Angus Energy.
Under the agreement, FFBRA said Angus must pay 100% of the costs until oil is produced (stage 1), while Cuadrilla would pay 75% of the costs in stage 2. The association said:
“This means Angus is incentivised to push as much of the cost as possible into Stage 2.”
It said Angus had provided only a “design philosophy” for stage 2, rather than engineering details and calculations.
“Angus are asking the council to grant permission on the basis of a general wish list and conceptual ideals rather than concrete design plans. A bit like architectural pencil illustrations rather than the engineering designs.”
FFBRA’s review said it had identified:
“several significant shortfalls and concerns about the thoroughness and robustness of the hydrogeological risk assessment”.
It concluded there were:
“several constructs … concerning the hydrogeology beneath Balcombe that lead to potentially spurious and subjective opinion rather than wholly evidence based objective assessment of the risks”.
Mitigation measures, based on these constructs, “mat not be sufficiently robust to thoroughly mitigate the actual risks”, it said.
The FFBRA review said the risk assessment simplified the hydrogeology of Wadhurst clay, influencing the attitude to risk and monitoring.
It also said misleading and inadequate groundwater sampling results were used to conclude that the Ashdown Beds aquifer were poor quality for drinking.
Balcombe Parish Council refuted the statement in the risk assessment that there were high methane and ethane concentrations in 1986 when the Balcombe 1 well was drilled.
“The aquifer has a long history of supplying water to our area and we can find no evidence of methane related problems. The aquifer is now a secondary reserve for the area but this is due to its limited flow rate not its quality.”
It said large increases in methane in 2019 compared with 2013 were beyond what would be expected from natural variations.
“This is almost certainly due to the well-drilling and associated operations started in 2013. If these unconventional operations have already had this effect on the ground-water samples, we are concerned about the impact of continuing pollution. The risks to groundwater are too great to allow these operations to continue.”
The council said there had been inadequate water sampling and testing to establish baseline figures and called for a longer data set.
“Lack of clarity on acid”
Balcombe Parish Council also called for clarity on the intended use of acid.
It said the plans show acid storage tanks but there was no mention in the application about the use of acid in stage 2. It requested information on the amount of acid that would be used and stored.
Lack of detail on restoration
The application failed to comply with West Sussex’s joint minerals plan because it did not provide detailed information on restoration, the parish council added.
Angus Energy response
Angus Energy published a response on its website on 12 February 2020:
“Whilst we applaud the care and interest taken by local groups, at least as regards fears of contamination of water supply from unintended migration of oil around the drilled hole, we repeat that there is in excess of 1,000 feet of robust steel casing and good cement bonding to the surrounding rock between those depths at which oil extraction is intended to take place and any conceivable water source.
“We also re-iterate that the proposed operations do not involve making any new communications between different subsurface layers, as for instance by drilling, but rather focus solely on extraction. The action of extracting, of course, reduces the pressure in the hydrocarbon reservoir and therefore long-term risks to well integrity.
“Finally we note that there has, to the best of our knowledge, only been one site in the UK onshore in the past thirty years which has experienced failure of well integrity resulting in any pollution and this was in fact due to failure near the surface well cellar rather than cement failure deep downhole which is the focus of local concern. Over 2250 wells have been drilled in the UK in the last century and well design has constantly improved.
“We are confident that our Hydrogeological Risk Assessment fully and professionally addresses all of these issues.”
Updated on 12 February 2020 with responses by Angus Energy to comments on risk assessment