Narrabri Gas

As the member of a farming family I am very opposed to any activity that appears to disturb our natural landscape to the detriment of the wildlife and is likely to upset the balance of our precious water resource's. We are the driest continent on this earth and water is our life blood, to put it at risk, in any form, and for short term monetary gain is madness. I very definitely object to this Narrabri Gas Project and wish to have my objection considered.

PLEASE USE THIS SUBMISSION TEMPLATE -
Submission: NARRABRI GAS FACILITY - CHAPTER 25 HAZARD AND RISK ASSESSMENT

Dear Sir/Madam
I object to the Narrabri Gas Project on the grounds that Santos has not properly assessed the major hazards and risks of the project, in that it has incorrectly applied the techniques of EPP33 and HIPAP 4, when the correct legislation it needs to comply with is Chapter 10 of the Work Health and Safety Regulation 2011 - Major Hazard Facilities.
EPP33 and HIPA4 are no longer the relevant legislative standards applicable to major gas/LNG processing plants in NSW. The correct legislation is the Work Health and Safety Act.
Leewood gas processing plant needs to be regulated as a licensed major hazard facility and undertake safety case assessment as required by the Work Health and Safety regulation 2011. Santos will be handling over 10% of a `Schedule 15' chemical i.e. methane. In addition, the gas processing equipment, wells, compressor stations will generate air toxics which need to be adequately safety-cased.
This legislation requires notification to WorkSafe NSW, licensing and production of a detailed safety case to ensure onsite and offsite risks to the public, workers, property and the environment are MINIMISED (as low as reasonably practicable).
The tests applied by the guidelines EPP33 and HIPAP4 are INADEQUATE to ensure safety and risk minimisation to the nearby suburbs of Narrabri. It is noted that a primary school, Narrabri West, is within a few kilometres of the active gas field and approximately 10 kilometres from the Leewood gas processing facility.
Santos has not adequately assessed, and as a consequence, not adequately mitigated the risks to the public, workers, plant and the environment of methane explosion, catastrophic toxic untreated produced water loss of containment, catastrophic air toxics cloud production and plant failure such as well blow outs, pipeline rupture, gas processing plant failure, compressor failure etc.
The Project should be rejected out of hand as inadequately assessed.
I note that even using the incorrect and out-dated legislative techniques, Santos has identified at least one `sensitive receptor' 350 metres from the boundary of Leewood at risk from `uncontrolled containment of gas'.
Further, Santos has identified a `moderate' level of bushfire risk with a potential to cause large bushfires. Again, this risk has been subjectively assessed and claimed mitigation measures are un-tested. Santos's own subjective `risk assessment' may not be acceptable to the surrounding community and inadequate to ensure protection of bushland areas.
There is no analysis whatsoever of lack of containment of air toxics from either catastrophic or normal operation of the gas processing plant at Leewood.
Santos has failed to adequately assess the safety of the untreated toxic coal seam gas produced water dams which are proposed to be re-built at Bibblewindi, nor of the risk of flood or loss of containment at the vast Leewood brine storage dams. Both of these areas risk contamination of the Namoi catchment area and the Narrabri town water source.
Unless an adequate safety case is approved by WorkSafe NSW in accordance with licensing requirements of the Major Hazard facility regulations, this project must be rejected out of hand and NOT approved.

Yours sincerely,
Marany Chan

Please do not allow CSG mining in the Pilliga. Your decision will influence my decision at the next election.

For many years I have been a successful Geohydrologist and Groundwater engineer both in Government service and Private practice. Also I have since 2001 I have been concerned about the projections of CSIRO on the effect of global warming on conditions in Australia. See my long study on the effect of global warming on people in seven Australian Cities by entering - environmental papers from Cecil Forbes.
My greatest concern apart from the contribution escaping Methane and Carbon dioxide from the burning of the coal seam gass is the effect on forest and farmland in the areas being considered for development. I am concerned particularly about what methods of disposal are proposed for the water that will be produced in the gas production process should that water be unsuitable for domestic, local industrial or irrigation.
I realise that in the interim period before we convert to the use of sustainably produced electricity for all domestic and most industrial use gas wilol be required but such gas should be sourced from Australias already developed gas sources.

CSG is crime against humanity, end of story. It 100% destroys the very essence of human life - WATER.

That we are still defending this basic human right as if it was negotiable speaks volumes about who actually runs this country/world.

Shame on you all!

This is over our Great Artesian Basin, the life blood of Australia, and you want to drill through with the possibility of contamination, I DONT THINK SO. Let alone with all the salt by-product, where is that going? to create more waste land somewhere. Cattle and humans cant drink salt water, the majority of plants die absorbing salt water. SO WHY DO SOMETHING LIKE THAT, just for a company to make a few more dollars and to send a lot of this gas over seas to other countries, where they are able to buy gas after being transported all that way, cheaper than what we Aussies can buy it for here.

The Gamilaraay Traditional Custodians are opposed to the CSG did you not take that into consideration.

Now on Nasa's site it says that methane's effects on global warming are about 84 to 87 times higher than Carbon dioxide now they say that methane only sticks around in the atmosphere for decades, rather than centuries like carbon dioxide, but it absorbs much more heat. Are we not trying to reduce our carbon footprint to reduce that heat. So why add more methane. And I look at it this way Plants need carbon dioxide to produce oxygen, not methane to make oxygen.

To make the area fire safe, there would have to be extensive clearing, around the methane fire stacks, as well as the roads for travelling in and out of the area. The methane stacks could not be shut down in severe bush fire times or total fire bans, therefore placing lives in considerable danger. Therefore if any lives, livestock or property was damaged in these fires, The Govt. should be held accountable for allowing this project to go ahead. And therefore could be sued for billions of dollars is that worth the small amount that you would be making from this small increase now. Besides the fact that you would have that on your conscience forever. By clearing such an area, to allow for the production of the gas and fire safety, seems really two faced, as other land holders, have been unable to clear certain areas, for buildings, or to increasing their farming.

Santos has already contaminated a freshwater aquifer in the Pilliga with uranium at levels 20 times higher than safe drinking water guidelines, as well as lead, aluminium, arsenic and barium². In addition, there have been over 20 reported spills and leaks of toxic CSG water from storage ponds, pipes and well heads. Santos cannot be trusted.

PLEASE PLEASE DO NOT LET ANY CSG PROJECTS GO AHEAD

Time to start doing more solar, or think outside the square, not keep raping and pillaging the land.

See attachment

Water is one of the most basic requirements for life. I object to the Great Artesian Basin being put at risk.

I have a business in Narrabri that services rural and urban customers in the Narrabri Shire.
Due to drought over the past few years most farmers have had their incomes severely affected and many have had to look for off farm work. Fortunately, both coal and CSG has been a source of employment for these people in the Narrabri Shire. The income has enabled them to keep their farm. As well as being able to keep their farm they may have some extra money that will be spent in Narrabri or Wee Waa; which maintains the survival of many retail businesses.
Businesses in Narrabri and Wee Waa have struggled in recent years. We have been fortunate to have a CSG and coal mine industry to help them stay viable and survive.
When businesses in small towns suffer, this affects school enrolment numbers (meaning less teachers), employment of young people and many other cut backs.
Narrabri Shire Is a strong agricultural area, but needs CSG to maintain growth of the town and district. Small country towns do struggle due to many seasonal variations and a good balance of industry is important for them to survive and prosper. I want my children and grand-children to be able to get a job now and for many years to come

As a retired engineer I have read all articles that I have come across on the long term effects of fracking. There does not appear to be conclusive evidence that there will be no ill effect on the water table.
If even the slightest doubt exists then it must be stopped. The risk is too great as any poisoning damage could take a long time to show and would by then be extensive and cannot be undone.
The future of agriculture and the welfare of our farmers must be the overriding consideration of all levels of government.

The short sighted foolishness of endangering prime agricultural land with CSG contamination must stop once and for all. Our long term economic future lies in efficiently producing food for an expanding world market. This must not be jeopardised by the short term politicised goals sought by CSG exploiters.

I spent some time in the area in and around Narrabri, Wee Waa, Coonamble up to Moree working for both State & Aust Governments of the time which included travelling through & staying in camps in the Pilliga area, this area is susceptible to any dramatic change other than nature especially mechanical equipment movements which I observed in my time in the area only movements by those on foot did not cause any environmental damage. Exploration & any possible works wether above or below the natural ground line will have a detrimental consequence on the flora & fauna within an area having huge subterranean water source which dependant on many influencing occurrences of nature ensures that the flora & fauna survive in what can be a harsh environment at times any impact via exploration or mining will ensure the demise of the sustainability of the entire area.
The area where proposed exploration is planned needs to be protected at all cost to ensure the longevity & a balanced environment can survive any exploration & or mining will cause a great burden when there is drought or flood which the area is susceptible & I have experienced in my time working in the area.
ANY MINING OR OTHER POSSIBLE IMPACTS SHOULD BE STOPPED TO ENSURE ENVIONMENT SURVIVES

I object strongly to this project. No more gas projects

There are 5 very good reasons to reject the Pilliga CGS project. I list these objections below:-

1. The Pilliga is a safe haven for threatened wildlife
The Pilliga is one of 15 nationally listed `biodiversity hot spots' and is vital to the survival of threatened species like the koala, spotted-tailed quoll, black-striped wallaby, eastern pygmy-possum, pilliga mouse and south-eastern long-eared Bat. These native animals can only live and thrive in this area. Once it is polluted their habitat is gone and these precious native animals die. Why should they die because CSG companies want to profit by exploiting our natural resources. These profits mostly go overseas and the mining companies provide little taxation into Australian coffers.This is a lose, lose situation, - a total disaster in the making.

2. Coal seam gas fuels dangerous climate change because
Methane is by far the major component of natural gas, and is a greenhouse gas 72 times more powerful than CO². CSG fields contribute to climate change through the leakage of methane during the production, transport, processing and use of coal seam gas. It is nearly impossible to stop the leakage of methane during extraction processes.

3. It risks our clean water
The Narrabri gasfield poses a real risk to our two most precious water resources: the Great Artesian Basin and the Murray-Darling Basin. The area of the Great Artesian Basin with the highest recharge rates is almost entirely contained within the Pilliga East forest. Australian is a dry continent and all Australia - human, flora and fauna need access to clean water. If these key water resource areas are polluted it is a major problem for all Australians, native and human, who rely on this water supply for drinking, household use, farming and agriculture.

4. The Gamilaraay Traditional Custodians are opposed
There are hundreds of cultural sites as well as songlines and stories connecting the Gamilaraay to the forest and to the groundwater beneath. Gamilaraay people are deeply involved in the battle against CSG, and have told Santos they do not want their country sacrificed for a coal seam gas field. The Gamiilaraay eoples have lived in harmony with nature for 40,000+ years. Europeans have successfully damaged our Australian environment for over 200 years. The CGS project will achieved total destruction in less than a decade for Santos shareholders.

5. Bushfire risk will rise
Methane flare stacks up to 50m high would be running day and night, even on total fire ban days. The Pilliga is already prone to severe bushfires, this project will increase the risk of ignition to an area already at huge risk of bush fires.. Local communities in this region already live with high bush fire risk - why put them under even more threat for Santos profit?

Thank you for this opportunity to raise my concerns and objections to this project. No CSG mining in the Pilliga thank you.


Lesley Killen (Ms.)

I am very concerned about the protection of our land & water.
These are things which cannot be tampered with & are the real wealth of the country.Organisatios which stand to make large sums of money,even if they say all the environmental safeguards have been met just aren't to be trusted.
What happens if our water becomes contaminated & undrinkable.No amount of profit is worth clean water & land.
Future generations are relying on us to make the right choice.It's a no brainer!

Santos has already proved that it can get away with its don't care attitude, by "losing" toxic tailings. It's just not worth risking our forests and groundwater by allowing fracking.

The Narrabri gasfield poses a real risk to our two most precious water resources: the Great Artesian Basin and the Murray-Darling Basin. The area of the Great Artesian Basin with the highest recharge rates is almost entirely contained within the Pilliga East forest. In a worst-case scenario, the water removed for CSG extraction could reduce water pressure in the recharge areas--potentially stopping the free flow of waters to the surface at springs and bores across the whole Great Artesian Basin.

Creeks in the Pilliga run into the Namoi River--a part of the Murray Darling Basin. This system is vulnerable to contamination from drilling fluid spills and the salty treated water produced from the proposed 850 wells.

There are hundreds of cultural sites as well as songlines and stories connecting the Gamilaraay to the forest and to the groundwater beneath. Gamilaraay people are deeply involved in the battle against CSG, and have told Santos they do not want their country sacrificed for a coal seam gas field.

Extensive community surveys have shown an average of 96% opposition to CSG. This stretches across a massive 3.2 million hectares of country surrounding the Pilliga forest, including 99 communities. Hundreds of farmers have participated in protest actions unlike any previously seen in the region.

Santos has already contaminated a freshwater aquifer in the Pilliga with uranium at levels 20 times higher than safe drinking water guidelines, as well as lead, aluminium, arsenic and barium. In addition, there have been over 20 reported spills and leaks of toxic CSG water from storage ponds, pipes and well heads. Santos cannot be trusted.

The Pilliga is one of 15 nationally listed `biodiversity hotspots' and is vital to the survival of threatened species like the Koala, Spotted-tailed Quoll, Black-striped Wallaby, Eastern Pygmy-possum, Pilliga Mouse and South-eastern Long-eared Bat. The forest is home to over 200 bird species and is internationally recognised as an Important Bird Area. The Santos gasfield would fragment 95,000 hectares of the Pilliga with well pads, roads, and water and gas pipelines--damaging vital habitat and threatening the survival of endangered species.

Furthermore, Coal seam gas fuels climate change. Methane is by far the major component of natural gas, and is a greenhouse gas 72 times more powerful than CO². CSG fields contribute to climate change through the leakage of methane during the production, transport, processing and use of coal seam gas.

A range of hydrocarbons and volatile organic compounds can be released into the air from coal seam gas operations, including flaring of gas wells. The effects of volatile organic compounds vary, but can cause eye, nose and airway irritation, headache, nausea, dizziness and loss of coordinatio. These impacts have been documented in human populations nearby to existing gasfields in Queensland, Sydney and in America.

I am sick of those who are elected to represent the majority of this population constantly acting out of their own interests and in the interests of those who are clearing funding their future retirement!

Please keep Santos out of the Pilliga. The environmental is too precious!

1. The Narrabri Gas Project risks precious water sources, including the Great Australian Basin--Australia's largest groundwater aquifer
The Narrabri gasfield poses a real risk to our two most precious water resources: the Great Artesian Basin and the Murray-Darling Basin. The area of the Great Artesian Basin with the highest recharge rates is almost entirely contained within the Pilliga East forest. In a worst-case scenario, the water removed for CSG extraction could reduce water pressure in the recharge areas--potentially stopping the free flow of waters to the surface at springs and bores across the whole Great Artesian Basin.¹

Creeks in the Pilliga run into the Namoi River--a part of the Murray Darling Basin. This system is vulnerable to contamination from drilling fluid spills and the salty treated water produced from the proposed 850 wells.

2. The Gamilaraay Traditional Custodians are opposed
There are hundreds of cultural sites as well as songlines and stories connecting the Gamilaraay to the forest and to the groundwater beneath. Gamilaraay people are deeply involved in the battle against CSG, and have told Santos they do not want their country sacrificed for a coal seam gas field.

3. Farmers and other local community reject the project
Extensive community surveys have shown an average of 96% opposition to CSG. This stretches across a massive 3.2 million hectares of country surrounding the Pilliga forest, including 99 communities. Hundreds of farmers have participated in protest actions unlike any previously seen in the region.

4. The Narrabri Gas Project has a long history of spills and leaks of toxic CSG water--Santos cannot be trusted to manage the project safely
Santos has already contaminated a freshwater aquifer in the Pilliga with uranium at levels 20 times higher than safe drinking water guidelines, as well as lead, aluminium, arsenic and barium². In addition, there have been over 20 reported spills and leaks of toxic CSG water from storage ponds, pipes and well heads. Santos cannot be trusted.

5. The Pilliga is a haven for threatened wildlife
The Pilliga is one of 15 nationally listed `biodiversity hotspots' and is vital to the survival of threatened species like the Koala, Spotted-tailed Quoll, Black-striped Wallaby, Eastern Pygmy-possum, Pilliga Mouse and South-eastern Long-eared Bat. The forest is home to over 200 bird species and is internationally recognised as an Important Bird Area². The Santos gasfield would fragment 95,000 hectares of the Pilliga with well pads, roads, and water and gas pipelines--damaging vital habitat and threatening the survival of endangered species.

6. Coal seam gas fuels dangerous climate change
Methane is by far the major component of natural gas, and is a greenhouse gas 72 times more powerful than CO². CSG fields contribute to climate change through the leakage of methane during the production, transport, processing and use of coal seam gas.

7. Human health is compromised by coal seam gas
A range of hydrocarbons and volatile organic compounds can be released into the air from coal seam gas operations, including flaring of gas wells. The effects of volatile organic compounds vary, but can cause eye, nose and airway irritation, headache, nausea, dizziness and loss of coordination⁴. These impacts have been documented in human populations nearby to existing gasfields in Queensland, Sydney and in America.

8. The nation's premier optical astronomical observatory is at risk
The Siding Springs Observatory, situated in the Warrumbungles and adjacent to the Pilliga, is under threat from the Narrabri Gas Project due to light and dust pollution⁵. The area has been internationally recognised as a `dark sky park'⁶ and the 50m high gas flares proposed by Santos threaten the viability of the facility.

9. Thousands of tonnes of salt waste will result from the project
Santos has no solution for disposing of the hundreds of thousands of tonnes of salt that will be produced. Between 17,000 and 42,000 tonnes of salt waste would be produced each year. This industry would leave a toxic legacy in NSW.

10. Risk of fires would increase throughout the Pilliga's tinder-box conditions
Methane flare stacks up to 50m high would be running day and night, even on total fire ban days. The Pilliga is prone to severe bushfires. The project would increase ignition sources as well as extracting, transporting and storing a highly flammable gas right within this extremely fire-prone forest.
- See more at: https://www.wilderness.org.au/final-push-pilliga#sthash.vDEqF8Es.dpuf

The whole of the Piliga is essential to be retained as natural.
850 wells is abominable!
And attacks on the Great Artesion Basin should not be allowed - we are the driest continent and need all our water uncontaminated.

Lets not sell our soul to foreign investment.