Europa Oil has applied to the Environment Agency for an environmental permit covering the storing and handling of crude oil and radioactive substances arising from its planned drilling at Leith Hill
You can read the documents – including a non-technical summary – and submit your response to the Environment Agency consultation here:
https://consult.environment-agency.gov.uk/psc/rh5-6hn-europa-oil-and-gas-limited/
The deadline for responses is 16 May.
Residents and campaigners believe that any risk of radioactive or acid waste leakage on Leith Hill is unacceptable. The site is within an Area of Outstanding Natural Beauty and should have the highest status of protection in law. The plan makes it clear that radioactive waste will be trundled out on HGVs but no traffic management plan has even been submitted. Local campaigners have produced some pointers to help you respond.
Water catchments
The EA’s water safeguard zone (map here) and water catchment area (map here) maps show that the proposed drilling site is located directly next to a Surface Water Safeguard Zone and in the catchment area of the Pipp Brook directly upstream of a Groundwater Safeguard Zone. The potential impact of this location to the local drinking water supply has previously been highlighted by Sutton and East Surrey Water .
Low risk?
In the Environmental Risk Assessment, the applicant identifies a number of Possible Sources of Accident with consequences of polluting the groundwater or surface water. They then claim that the overall risk is low providing the correct management techniques are followed. They propose that they should be exempt from needing a groundwater permit. However:
- Even if the probability of an accident is low, given the proximity of the water safeguard zones then the impact of any such incident will be very large.
- No consideration is given to accidents relating to a failure to follow correct management techniques. What secondary measures are being implemented to reduce impact in the instance something does go wrong?
Compound and long-term risks
There is no indication of linked and/or compound risks in the Risk Assessment. Clearly the risks are not all completely independent. How is the risk of a contamination incident increased by fire for example?
Only short-term risks resulting from failures of storage tanks or pipe ruptures are considered. What about the risks from well casing failures? There have been many instances of boreholes failing and becoming conduits of water contamination. In the longer term these represent a greater risk than storage tanks rupture, but they are not mentioned at all.
Groundwater pollution risks
In the Waste Management Plan, the applicant is requesting exemption from having to apply for groundwater permit on the basis that the quantity of the acidisation pollutant would be small. However, the applicant only specifies the volume of acid per foot. What is the total volume they will be using? Also what about the other chemicals such as the anti-corrosives, surfactants and demulsifiers used in the acidisation process? These are also clearly contamination sources.
Liability insurance
What is the limit of the applicant’s liability insurance? Has the applicant sourced independent estimates of the clean-up costs of each risk identified in their Risk Assessment? Do any of these exceed their liability limit? In the instance that the applicant decided to cease trading following a contamination incident, what insurances would remain in place and for how long?
How to respond:
- Online on the Environment Agency website
- Or send an email with subject Application No: EPR/YP3735YK/A001 to pscpublicresponse@environment-agency.gov.uk
Keep in touch with the campaign:
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