Narrabri Gas

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Objection submission uploaded

Attention : Executive Director - Resource Assessments and Business Systems Dear Sir/Madam , Thank you for the opportunity to comment on the the Santos Environmental Impact Statement [Narrabri Gas Project] - Application No. SSD6456 I am appalled at first glance at the Santos EIS that it states that the project area is nowhere near either the Great Artesian Basin { GAB } or a critical recharge area for the GAB , please see attachment . This is such a glaring misrepresentation of the truth and deception of the facts that this alone should prevent this Project from any further consideration . The next is that this project can co-exist with the existing land use that is already occurring in the project area , agriculture, national & state parks , temperate forest , grassy box woodlands , underground aquifers, groundwater resources , infrastructures , heritage sites ,conservation areas & urbane development . Attached is a report prepared by the Coal Resources Development Committee in 1994 called " Effects of Land Use on Coal Resources " and it categorically states that Land Uses Affecting Coal Resources are Agriculture & National Parks / i.e.; Food & the Environment !!! What a sad Inditement on this whole Industry that it espouses that it is more important the current sustainable land use. Of critical Importance when examining the Santos EIS is the matters of {a} Produced Water & it's proposed use & {b} the Brine or Salt that there is no reasonable solution for. Attached is Water Sample Result taken out of evaporative & holding ponds in the project area with absolutely no connection with any treatment facilities or Reverse Osmosis Plant { RO Plant } and was taken just before Santos took over the whole project from Eastern Star Gas , ESG but still had a 20% + holding in the project and represents a true & accurate analisyst of the water composition , also it was taken in the presence of a Federal Senator and the sample was analysed by a reputable & recognised Chemical Analytical Laboratory also attached are comments regarding the findings by John Polglase Hydrogeologist confirming the Laboratory results and it's unsuitability for irrigation use. Concerns re Brine & Salt remediation & solutionsBrine Disposal & RO Concentrate Disposal
Brine management is a major bottleneck for coal seam gas (CSG) production in Australia . Solid Waste remains, even after 10-15 years of CSG extraction in Queensland, a significant logistics and disposal issue for desalination solid waste and chemical processes .
There is currently no treatment-disposal mechanism in place in Australia for the concentrated (solid salt-waste) produced after the reverse osmosis of CSG brine . This fact will create a legacy issue that the industry will, in all likelihood, pass on to the New South Wales taxpayer .
The Narrabri Gas Project should not be approved based on this issue alone.
Figure 1- Treated Water Management Options - Santos Narrabri Gas Project EIS
According to the EIS disposal could involve an estimated 110 tonnes PER DAY brine being sent to a registered contaminated waste dump/third-party landfill and/or 2 tonnes toxic of brine PER DAY being discharged into Bohena Creek.
The EIS states that the concentrated solid waste from the NGP Reverse Osmosis plant will be disposed of at a "Licenced Facility".
Using a licenced facility does not make the waste disposal issue miraculously disappear. Santos simply hands the problem on to someone else.
The eventual fate and impact of this RO brine concentrate in the environment is not scientifically dealt with in the EIS.
The ultimate fate of CSG solid salt/waste in landfill is correctly described by Qld farmers as a "recipe for disaster" .
The table below shows the dramatic increase in waste residues in Qld as a result of the CSG industry:
(Table 1- Waste disposal - Historical data - Qld)
The miscoding of the CSG solid waste stream is an identified issue in Queensland; this miscoding masks a serious issue regarding the tracking and ultimate fate of CSG industry waste.
The option of creek-flushing to dilute produced water into the environment (using Bohena Creek as an industrial drain) is purely a corporate cost-cutting measure; the objective of which is to maintain gas supply and avoid creating (and paying for) the storage and alternative disposal of the toxic RO salt concentrate.
The following except from the 2016 Blyth Creek (Qld) EA Amendment Application clearly states maintaining gas supply (economic), not environmental protection, is the primary objective of creek-dumping:
"The greatest risk to gas supply objectives are during very wet periods (e.g. 3-4 months when soils remain saturated following multiple rainfall events) is when no produced water can be utilised for irrigation. No amount of irrigation area can manage this risk. Critically, GLNG seeks the additional authorisation for the event-based release of produced water to Blyth Creek during flow events, as a sustainable water management option for produced water during wet weather and as waste avoidance and minimisation strategy that does not result in the generation of waste brine and solid salt."
There are a significant number of issues involved in stream-dumping of CSG waste and resultant bio-toxicity. For example, organic compounds and radionuclides Uranium 238, Radon 226, Radon 228 and Potassium 40 were detected in the raw CSG water and in the RO brine in Qld. The Healthy Headwaters Hazard Characterisation (2012) stated that there are currently limited guideline values against which to assess the biological relevance of the radionuclides detected.
Given the variability of waste constituents across all wells within a gas fields and over the lifetime of a gas field; creek dumping of waste will require careful and costly monitoring. Given the economic constraints that are affecting the industry; ongoing allegations of environmental "cover-ups"; CSG companies choosing to pay fines rather than undertake costly remediation; it is questionable as to whether these necessary acts will be undertaken in a rigorous manner over the coming years .
The economic success of the NGP relies on contiguous field developments which extend beyond the scope of this EIS Also of concern is the fact the Pilliga Forest is the largest & last remaining Temperate & Remnant Woodlands & Habitat to many critically endangered species of Fauna & Flora . Of greatest concern is that of the Iconic Koala which this region is blest with and is under threat from increases in temperature and projects such as this.1. 'Not there'. Santos are saying while there are some Koalas left in the Pilliga, they aren't anywhere near the project area, as surveys done by Santos did find any sign of them apart from a skull. This is not correct as three independent surveys gives four records in the project area in the last three years and three more south of the project area but on the same creek system. This includes two sitings of animals.
2. EIS gets the habitat wrong by missing 7 000 ha of Pilliga Box woodland primary habitat across the north of the forest. Their own koala expert said this but was ignored by the senior consultants (EcoLogical Australia) in their habitat mapping.
3. Koalas are not doing well and are endangered with extinction in the Pilliga, the actions by Santos are not helping, particularly by making out that Koala distribution in the forest is much less than it really is.
The next is some key points relating to impacts on aquatic ecology and groundwater dependent ecosystems. 1. Bohena Creek is not generally in poor condition as claimed by Santos. Surveys found while some areas show dieback, most parts of the creek are in a good condition, supporting old growth red gum-rough-barked apple woodlands and many semi-permanent waterholes (about 30) which have a high biodiversity and local significance to wildlife.
2. Hydrological modelling on the impacts of treated water release into Bohena Creek relies on a principle of maximum dilution during periods of high flow but ignores the fact that surface flow can be trapped in creek features and can rapidly sink into the shallow aquifer which underlies the creek system. No assessment has been undertaken on the impact of polluted water within waterholes, which get recharged during periods of high flow.
3. The EIS states that depressurisation of aquifers may result in a drop of 0.5m, though is likely to increase over time. Even a drop of 0.5m could have significant impacts on the permanence of some waterholes and shallow water tables associated with alluvial areas. However the modelled drawdown impacts on groundwater in the EIS is not credible given lack of supporting data.
4. It seems a stygofauna survey was conducted in a way to minimise the chances of obtaining results, with poor coverage of 'control' areas. Independent surveys as recently as 2013 discovered new species and areas of high diversity. To claim that there will be no impact on stygofauna is not credible given this lack of information and given questions relating to the modelled groundwater drawdown and treated water release.
5. Invertebrate and fish surveys have been poorly done with no sampling from good condition waterholes on Bohena Creek. The survey missed a key species, the freshwater mussel Velesunio ambiguous, a strong indicator of good health and permanence of these waterholes. These holes also provide refuge for the native fish, freshwater sponges and a range of invertebrates which rely on good water quality.
6. Santos have contra

Submission via attachment in link below

Making this Submission on behalf of the Farming Partnership Business I am both a Partner in as well as Manager , I would like to formally object to any further consideration being given to this Project as it will not only impact on the value of the Country we conduct our Agricultural Business on but to the actual economics of the Business itself as stated in CSRIO report on cost of CSG to Agricultural Producers in Queensland where it has average out at an average cost or net loss to individual agricultural businesses to the tune of $!.6 million+ . Also GISERA reports that for every 10 jobs the CSG Industry creates { in Construction Only } 18 Jobs in Agriculture are permanently lost for good . Also please see attached file regarding CSG Health Risks to Humans & Animals and realise that the approval of this project will immediately impact on the Consumer desirability of Agriculture Products produced in this region . thank you David Quince on behalf of " DM & MH Quince Partnership "

Attn: Executive Director, Resource Assessments
NSW Department of Planning and Environment
GPO Box 39
Sydney NSW 2001

I object to this project and believe it should be rejected by the NSW Government on environmental grounds. The EIS does not address the significant damage that the Narrabri Gas Project will have on the natural, social and economic environments of northern NSW.

Please find my complete submission, including the reasons why I object to the application in the attached file.

Yours sincerely,

Garth Philip Newton