MARKWELLS WOOD WATCHOBJECTION 27 MARCH 2017
RESPONSE TO UKOG ADDITONAL INFORMATION
Application No. SDNP/16/04679/CM
Appraisal and production of oil incorporating drilling of one side track well from existing, three new hydrocarbon wells and one water injection well, and to allow production of hydrocarbons from all four wells for 20 years: Markwell's Wood, Forestside,Rowlands Castle, West Sussex.
SDNP REQUIREMENTS FOR CLARIFICATION/FURTHER INFORMATION / UKOG RESPONSE / MARKWELLS WOOD WATCH COMMENTS- Site development: plan to show the direction of the new side-track and 3 new oil wells
- Information on the technique of using hydrochloric acid to release hydrocarbons
- Evidence to show that alternative sites outside the National Park have been considered
- Detailed information on the potential impacts from volatile organic compounds (VOCs)
- Details of the volumes of hydrocarbons and transport:
2)How transported from site (road? pipeline?)
3)Highway impact of transportation of hydrocarbons
4)Other vehicle movements associated with the production phase
5)Analysis of vehicle movements for construction and dismantling
6)Use of TEMPRO suite to estimate background traffic growth
- Revised Groundwater Risk Assessment and Environmental Statement
risk assessment
2) How risks to groundwater are to be mitigated
3) Well abandonment
4) Detailed survey to identify features that may indicate karstic groundwater flow
5) Details of circulation losses from MW-1 in 2010.
- Revised Landscape and Visual Impact Assessment with the restored site as the baseline
- The impact of noise and vibration on bats
- Impacts on the surrounding Ancient Woodland, including pollution through run off and change to the water table
- Climatic impacts resulting from greenhouse gas emissions, including vehicle movements and flaring
2.“With regards to the request for further information on the technique of using Hydrochloric Acid to release hydrocarbons from the rock, the purpose of the acid treatment is to clean up the well perforations and remove near wellbore blockages (<2m radius of the wellbore) caused by carbonate mineral scale.
Acid treatment is a standard oil & gas industry practiceused around the world. The process is directly analogous to acidisation of boreholestargeting carbonate (e.g. chalk) formations,practised in the UK water-well industry.
Theacid treatment will involve the placement of 15% concentration hydrochloric acid (HCl) intothe wellbore and then into the well perforations in the oil bearingreservoir, approximately1600m below surface, within the oil-bearing reservoir.
The concentration of acid is similarto that found in domestic household cleaning products used in the UK.
The acid will not be forced into the reservoir.
The HCl will react with the oil reservoir carbonate minerals(limestones) to produce carbon dioxide gas (CO2), water (H20) and chloride ions (Cl-). Theprocess will result in the formation of carbonate salts and there will be no hazardous bi-products.
The oil bearing reservoir is separated vertically from the Chalk aquifer that is present at surface by over 1000m of predominantly low permeability, geological formations;and horizontally by three cemented steel casings which prevent migration of fluids from thewellbore. Consequently, the acid treatment will not constitute anyrisk to groundwater within the Chalk aquifer.”
(Environmental Statement Addendum para. 1.7)
3. Para 4.5 of the ES Addendum Non-Technical Summary remains unchanged and talks exclusively about the possible 12 sites within PEDL 126, which is entirely within the National Park.
4. The Air Quality Assessment Addendum (para. 2.18) states that UKOG’s intention is to flare gaseous hydrocarbons (methane and butane) on site and that the flare “will help to promote complete combustion and, thus, will help to minimise the release of gaseous VOCs from the flare” and that “extracted oil is unlikely to remain in on-site storage for any significant amount of time and that, as such, any fugitive VOC releases are also likely to be minimal.”
5. 1) The revised Transport Statement Addendum (March 2017) estimates 700 barrels of oil per day when all four wells are operational.
5. 2) The oil would be transported from the site by road and it is estimated that a maximum of 5 two-way journeys would be required per day (i.e. 10 vehicle movements in total) during the production phase.
5. 3) The increased HGV movement during the peak operational phase for 2017 and 2037 is estimated as 7.81%/6.71% on Finchdean Road and 10.64%/9.17% on Broadwalk, 22.73%/19.61% on the B2148, 4.46%/3.85% on the B2149 and 8.77%/7.58% on Emsworth Common Road.
5. 4) No details provided - regarded as “limited” (para.2.4).
5. 5) The HGV movements during construction/dismantling 2017/2037 are estimated as contributing an increase in HGV traffic of 22.73%/19.57% along the B2148, 4.46%/3.84% on the B2149 and 8.77%/7.55% along the Emsworth Common Road. Estimates for Finchdean Road and Broadwalk are given as 13.42% and 18.35% respectively but appear to be based entirely on estimates of 2037 traffic levels (table 2.2).
5. 6) The TEMPRO suite was used to project traffic growth.
6. 1) The significance of the risks of potential contamination are judged as ‘Major Adverse’ for the following aspects, activities and potential accidents: the chalk aquifer during enabling works; the drilling of new wells through the chalk prior to casing; the drilling of sidetracks; well casing failure; leakage of storage tanks; tankering hydrocarbons and recovered water from the site.
6. 2) The mitigation measures remain largely unchanged from the original application and reassert the impermeability of the on-site High Density Polyethylene Liner (HDPE), the integrity of the perimeter ditch, the safety of the well-casing technology, the use of bunded storage tanks and the traffic management plan. Risks are therefore judged to be ‘negligible’ or ‘minor adverse’.
6. 3) “ The well will be lugged and all cemented casings would remain in place.” (ES Addendum Non-Technical Summary, para. 9.8)
6. 3) Appendix 9.0 A Hydrogeological Risk Assessment, para. 9.53 states:
“The bulk permeability of the Chalk within the vicinity of the Site is likely to be lower in comparison to the Chalk lower down the catchment, due to less potential for solution weathering and karstic flows. Consequently, there is not the same potential for rapid groundwater movement from the Site to the public water supply at Havant and Bedhampton Springs as there is elsewhere in the catchment.”
6. 4) Comment is made about the fluid losses during the drilling of MW-1 as follows: “The only fluid loss was recorded at a depth of -20mAOD (~130mbgl), which suggests a higher permeability zone within the Chalk at this elevation. The exact reason for fluid loss at this depth is unknown but could be associated with the Lewes Nodular Chalk Member at the base of the Upper Chalk and/or the elevation of Pleistocene (Devensian) sea levels, both of which would be expected to occur at approximately this elevation.” (Appendix 9.1A Hydrogeological Risk Assessment, para. 5.6.4)
7. The planning application does give details of how the company plans to restore the site.
The Environmental Statement addendum states:“However, as operations are progressing, the appropriate assessment is the Site as existing, not the restored Site.”
Technical Appendix 5.1A Landscape and Visual Impact
Assessment, para. 2.11 states:
“Whilst the SDNP designation would infer a very high value in terms of designation, the absence of natural features within the site and the Ancient Woodland being confined to outside the site boundary fence, counterbalances the designation and downgrades the value of the landscape fabric and habitats is low.”
Baseline table EDP 2.1 now states:
“The site is within an area identified as having higher
tranquillity and lacks sky glow or illumination (see TA 5.8)
however the site itself has a considerably lower sense of
tranquillity given its current appearance as an empty oil
exploration site. This downgrades tranquillity from ‘very
high’” (to high).
Para 5.2 of the ES Non-Technical summary states that,“little correlation between the interior of the Site and this landscape character area (Wooded Estate Downland Landscape) was identified.”
It continues: “To the north, east and south of the Site, mature woodland curtails any visibility into the interior of the Site. The thin tree line along the western boundary reveals heavily filtered and screened views into the Site.”
Para. 5.3 now concedes that, “Significant effects have been
assessed on the Stansted and West Dean Downland LCA during site enablement, testing and drilling.”
Para 5.4 now states: “ HGV movements, in combination with the drilling rig would be visible and perceived as conflicting with a small part of the surrounding wooded ridges. This would impact upon local tranquillity and result in a significant effect local to the Site”.
Para. 5.5a conceded that: “Significant effects would be experienced by users of Public Rights of Way (PRoW); however, these are anticipated to diminish beyond 1km from the Site due to distance, intervening vegetation and topography. Furthermore, increased HGV traffic crossing PRoW would impact upon the tranquillity and amenity of routes resulting in an adverse effect. Drilling structures would change the view from the PRoW; however, effects during drilling of the Development would be temporary. Effects on minor roads such as Broadwalk will also be significant (although temporary) due to effects on generalamenity and tranquility.”
Chapter 5 Landscape and Visual Effects concludes:
“During site enablement, testing and drilling, the Development will conflict with policies relating to the landscape character and purposes of the South Downs National Park (Saved policy RE4 and R4 of the Chichester Local Plan; Saved Policy 12 of the West Sussex Minerals Local Plan and Draft Policies M12, M7a part ‘c’ and ‘iii’ and M13 of the emerging West Sussex and South Downs National Park Authority JMLP);
During production, the conflict with policies will be within a much smaller geographic area, affecting a smaller number of receptors; and due to the neutral effects on landscape fabric during site enablement, drilling and testing and long term beneficial effects following restoration, the Development will be compliant with policies or relevant parts relating to existing landscape features and restoration and aftercare (Saved Policy 53 of the West Sussex Minerals Local Plan; Draft Policy M7a, M23 and M24 of the West Sussex and South Downs National Park Authority JMLP).”
Chapter 6 Ecology and Nature Conservation, APPENDIX 6.2A PROTECTED SPECIES REPORT, 6.52,f states: “The impacts of noise and vibration on roosting bats have been scoped out of this assessment. There is no evidence that noise and vibration have a negative impact on roosting bats.”
The report continues: “certain species, including Bechstein’s bat are difficult to detect and this species may have been under-recorded. A precautionary approach has been taken in this evaluation and it is assumed that Bechstein’s bat do forage within the woodland adjacent to the Site. Based on the principles set out in Wray (2010)15 the bats are of County Local value.”
The report asserts that information about bat activity “has already been achieved using conventional techniques. The Ecology Addendum has taken a precautionary approach and assumed Bechstein’s bats do forage in the area.”
The report identifies 9 species of bats in this location.
Addendum 6.0A Ecology and Nature Conservation para. 6.52c states:
“The assessments presented in Chapter 8 Water Resources and Flood Risk, and Chapter 9 Ground Conditions and Groundwater conclude that there will be no pollution of groundwater or runoff and there will be no changes to the hydrological regime of the area or water table as a result of the Development. The impacts of polluted surface runoff and changes in groundwater on habitats, including ancient woodland, have therefore been scoped out of this assessment.”
5.67 The Arboricultural Assessment Appendix 5.6Apra. 5.67 statesthat there will be no loss of Ancient Woodland, trees or hedgerows during drilling. The effect is therefore neutral. Accordingly, there will be no significant effect on landscape fabric.
11. The Air Quality Assessment Addendum calculates that the combined CO2 emissions from site activities and from HGV movements would amount to a maximum of 3,704 tonnes per annum (para 2.14). This equates to approximately a half of one percent of the total emissions in the Chichester District Council area for 2014. Over the lifetime of the project the estimate is 71,744tonnes. / 1.No detailed and precise plan or description of the direction, length or gradient of the sidetracks is provided in the revised ES.
UKOG response: inadequate.
2. The information is incomplete and conflicting. Acidisation is a complex, multistage process. The applicant fails to provide meaningful information for each stage.
“<2 m radius of the wellbore” suggests matrix stimulation, not just cleaning. A clear distinction should be made.
The process is not the same as is used in the UK water business as it targets a much deeper layer of the geology with different minerals and with different reactive properties. There is a 6,000 ft difference between the aquifer and the target formation in the Oolite. As far as we are aware, the water industry does not inject large volumes of chemicals through a protected aquifer. The techniques proposed here appear to be unconventional and involve horizontal drilling.
The applicant states that the “oil bearing reservoir is 1600m below surface” This is the Kimmerage and would conflict with the description of the target formation by the applicant as the Great Oolite which is at 2,242m below the surface.
Clarification of the target formation is needed.
UKOG have not detailed volume of acids nor disclosed any of the chemicals, pressure, or porosity. Knowing the amount of fluids they are using (water plus acid) and what pressures they are planning to operate underare critical to understanding and assessing risk.
Research suggests that the amount of acid injected ranges from 25 to 250 gallons for each foot of formation. This would be equal 82,021 - 820,021 gallons of acids per well, the larger volume being more than an Olympic sized swimming pool.
Does this mean there will be no pressure used? How will this be achieved? This is vital to understanding the technique. More explanation needed.
What happens to the large output of CO2?
The flowback fluids are likely to contain pollutants, which pose additional risks, especially in the acidizing context. Unlike hydraulic fracturing the chemical concentrations in acidizing are high, ranging from 6% to 18%, and the waste returns can be highly acidic, in the range of pH 0–3. During these treatments heavy metals, salts, organic and radioactive material can be mobilized from the formation, by chemicals in the injection fluid.
This limestone is naturally fractured and fractures would provide pathways for fluid to flow deeper into the matrix and from the wellbore. They are potential pathways for contamination. UKOG has not identified these pathways in their risk assessment
UKOG response: inadequate.
3. No consideration is given to sites outside the National Park.
Despite UKOG’s response, which only considers alternative sites within PEDL 126,we consider that assessments should be made of sites outside the PEDL and outside the National Park.
UKOG response: inadequate.
4. This statement is vague. What if the VOCs released are not ‘minimal’? There is no analysis of the potential environmental impacts of any residual VOCs, the release of which would be unacceptable to residents.
UKOG response: incomplete.
5. The information provided about hydrocarbon production and the associated transport is insufficient.
We question the validity of the ATC data for 2017 (see Markwells Wood Watch Transport Statement) and argue that including all vehicles larger than 3.5t as HGVs is misleading. The risks to pedestrians, horse riders and cyclists from six axle articulated tankers is likely to be greater than from delivery vehicles or from farm traffic. We calculate, from UKOG’s data, that during the mobilisation and demobilisation of the drilling phase there would be one vehicle movement every 18 minutes.
West Sussex County Council Local Highway Authoritynotes in its objection (SDNP/16/04679/CM-HIGHWAYS/795608) that the traffic assessment fails to include: vehicles carrying contaminated process water; cars/vans during the operational phase; vehicles carrying non-crude product (possibly waste) during the operational phase; any allowance for maintenance traffic.
It therefore follows that the traffic figures are underestimates. This has not been addressed in the revised Transport statement addendum.
We contend that this proposal is a major project that fundamentally changes the nature of traffic in the area.
The TEMPRO transport model may not take into account the planned housing developments in areas that impact on the transport route such as at Westbourne, Oaklands, Horndean and Bartons Rise.
Traffic will increase significantly as will the potential for accidents to children, because of the location of Rowlands Castle Primary School, which is situated near the Whichers Gate junction of the B2148, B2149 and Redhill Road.
The traffic assessment does not provide any information about the risks of additional transport to cyclists, horse riders and walkers, vulnerable road users who use Broad Walk and Finchdean Road extensively.
The collision data identifies clusters of accidents on the Emsworth Common Road, the B2148 and the B2149. This is only a record of reported accidents (i.e. those involving injury or death) and no data is provided for Broad Walk or for Finchdean Road.There is no information about the risk of overturned lorries or tankers at any point along the proposed transport route. UKOG’s Appendix 9.1A Hydrogeological Risk Assessment identifies that the route traverses the chalk on Finchdean road and on Broadwalk (para.5.8.2). These omissions are therefore significant.Three accidents along Broad Walk involving HGVs were witnessed by local residents in 2016. Consideration should be given to the risks of contamination by overturned tankers carrying contaminated process water or hydrocarbons, as requested by Portsmouth Water.