Aquifer Interference, Fracked Baselines – Part 2

Part 1 of this report talked about the need for baseline water monitoring prior to coal seam gas (CSG) mining. We discussed the Plumb Rd site and the concerning levels of methane and hydrogen sulphide, amongst other analytes, that were recorded by government contractor StreamlineHydro. We also looked at the history of the site, the implications of historic gas mining activity on the water monitoring bores and how tax payer dollars are being spent. We will now examine the location of the ‘control’ sites and government implementation of the $22.8 million dollar project.

‘Control’ sites on the eastern side of the Pilliga are close to Narrabri long wall coal mine

Some 20km away from Plumb Rd the next Water Monitoring Bore (WMB) sites have been drilled on Scratch Road in Pilliga East Forest.

Doubts certainly exist about the Plumb Rd monitoring site’s ability to provide any baseline data due to its location and the credibility of these two new sites to be considered as ‘control’ sites, i.e. having natural uncontaminated conditions is also doubtful. They are in very close proximity to the Whitehaven Coal Narrabri Underground which has been degassing and dewatering coal seams in the area for several years. The Review of Environmental Factors (REF) is available here for the two new sites. Another monitoring site on Old Gunnedah Rd near Narrabri has also been completed by contractor Impax Drilling.

Site 14 Pilliga South Extraction Area rig & site 271019

The NSW Government appear to be scrambling and conducting expedited drilling of several monitoring bores with a 2020 deadline looming. The drilling is part of a 5 year coal seam gas baseline monitoring program. In the fifth year of this program there is still no baseline.

One startling fact emerges from the recent hearing of the NSW Parliamentary Inquiry into the Chief Scientist’s Recommendations on Coal Seam Gas is that the NSW Government is not using the Namoi Cumulative impact tool (NCRAT) developed by Namoi Catchment Management Authority, a custom built risk management assessment tool for cumulative impact of mining scenarios on bioregional assets in the Namoi Catchment. Utilising a total of 15 baseline sensitivity layersincluding groundwater & surface water quality, drawdown and flow, the NCRAT was designed to report the cumulative risk of any mining scenario constituting a combination of one or more mines including open cut mines, long wall mines, and coal seam gas operations.

The deliberate sidelining of a tool used to assess the cumulative groundwater risks of new mines and coal seam gas projects is a real concern for water governance and a dereliction of the Precautionary Principle. Both Michael Wright, Deputy Secretary, Resources and Geoscience and Tracey Mackey, Chief Executive Officer, NSW Environment Protection Authority were not aware of this tool prior to the Inquiry and they have undertaken to familiarise themselves with it.

Information is difficult for public to access

News story on Water Monitoring Bore sites in the Pilliga forest

Several print stories were published by media in relation to the choice of the Plumb Rd site. Some of these have since disappeared from the internet after reporting on community being unhappy with site selection. The media stories also mentioned the involvement of a government employee (at the time) who had previously been employed by Santos as a Land Liaison Officer and is now Stakeholder Relations Manager for OzMinerals.

A screenshot of one of the articles that is no longer available

As you’ve probably realised if you are still reading, the monitoring bore story is immensely complicated and confusing. There has been a profusion of project name, location and timeline changes as well as changes to the name of Government Departments responsible for producing the baseline. It is almost impossible to chart the lack of progress in regards to the program which is occurring at taxpayer expense.

The Narrabri Gas project should not proceed without trustworthy groundwater baseline data

If Narrabri Gas Project were to be approved in the absence of reliable baseline data about groundwater levels and quality, this would preclude anyone in future being able to prove damage by the CSG industry. So far only one site has been completed in the Pilliga area (on Plumb Rd) but is not fully operational. Very limited data is publicly available and limited to Standing Water Level. Promises that comprehensive ongoing data including BTEX would be made available from Plumb Rd have not been adhered to and we’ve seen just two sets of testing data. This is a serious failure and warrants a full investigation.

As background to this baseline drilling program read the Final Report of the Independent Review of Coal Seam Gas Activities in NSW by Chief Scientist Prof. Mary O’Kane produced in 2014. It highlighted the need for transparent and comprehensive monitoring of groundwater in regards to CSG operations. This gave rise to the the NSW Government Water Monitoring Framework.

Department of Primary Industries (DPI) Director for Water Information and Insights Dr Christobel Ferguson said in 2017 “Once operational this new bore will provide the community with access to the latest data on the region’s groundwater, and allow all parties to better understand and manage this crucial resource,” she said.

Parliamentary Inquiry into Chief Scientists’ Recommendations on coal seam gas

There is a parliamentary inquiry underway into the implementation of the Chief Scientists’ Recommendations on coal seam gas, but over five years later critical recommendations  remain unimplemented and farmers remain concerned for their water. 

Meanwhile, the rush is on to approve the Narrabri Gas Project which has undergone a protracted assessment period of over 2 years, delays mainly being attributable to Santos’ inability or unwillingness to provide information and assurances to various Government stakeholders. The community are aware that the Independent Planning Commission meeting/hearing for the Narrabri Gas Project could be called at any moment.

However, the ability of the lead regulatory agency on coal seam gas, the NSW Environment Protection Authority, has been called into question by the Parliamentary Inquiry.  A transcript is available of the Inquiry and this media story revealed that NSW government and public servants refused to appear. Mark Gifford, Chief Environmental Regulator was to be available for questioning but his name was removed from the schedule at the 11th hour and Tracey Mackey who has had very limited experience in coal seam gas, never having been to Narrabri, had to face the music on her own.

During the inquiry Mitchell Isaacs, Director, Office of the Deputy Secretary and Strategic Relations, Department of Planning, Industry and Environment, paints a favourable picture of progress in regard to monitoring saying: The New South Wales Government has invested $22.8 million in additional groundwater monitoring infrastructure, so new groundwater monitoring bores. That gives you geological data as well as water data at a number of levels and that is specifically for coal basins in New South Wales. There is additional data being collected and that data is available online in real time.”

However, this is not the case. The data is not available, despite statements by Mitchell Isaacs to the Inquiry.  In response to enquiries, Water NSW directly contradict Mr Isaacs, stating “It appears we only have hydrometric data for that site and do not carry out water quality analysis.” Mitchell Isaacs should correct his statement to the Inquiry.

Members of the Private Committee attending the Parliamentary Inquiry but Mark Gifford was not in attendance

There is little published data about hydraulic properties of Gunnedah Basin hard rock aquifers

According to Bioregional Assessments in 2018, regionally, groundwater gradients in the alluvial aquifers indicate flow from the east in a north-westerly to westerly direction away from the Namoi River (Parsons Brinckerhoff, 2011) and the groundwater flow systems within the major aquifers are generally local to intermediate in scale (CSIRO, 2007). Santos tend to agree with this but highlight the need for baseline studies.

There is little published information relating to the hydraulic properties of the Gunnedah Basin hard rock aquifers, so groundwater levels and flow paths are largely unknown. Generally, though, the flow is in a north-westerly direction, this raises questions about CSG wells impacting the Plumb Rd bore and the underground coal mine impacting the newer Scratch Rd sites.

The lead hydrologist at NSW Water has been asked to provide information on the groundwater flow direction but as yet has not responded to this request. Questions about what formation the department classes as the base of the Great Artesian Basin have also been asked and if a database of bores for the wider area that details their conditions exists. In Queensland there is a comprehensive groundwater database that shows basic parameters for bores.

Gunnedah Oxley Basin Cross Section, Conceptual Model, Bioregional Assessment, 2018

Does the NSW Government Water Monitoring Framework still exist?

The Framework was released in 2014 and subsequently a Fact Sheet detailing how Government would “transform how water data and information is captured and used to protect precious water resources”, independent oversight was to be provided by the State’s Land & Water Commissioner, Jock Laurie, recently sacked, from his position as drought coordinator for NSW.

The Fact Sheet is no longer available online and the promises of the Framework (as shown below) have not been fulfilled. It can be downloaded here as part of the documents associated with this article.


A screenshot of the proposed NSW Government Water Monitoring Framework

What is needed now?

It appears there is no guarantee that we will get the crucial baseline data required before CSG mining may be allowed to proceed at Narrabri, in fact it looks highly unlikely.

There is a need for independent detailed examination of all existing information, but when the Government appointed the Water Expert Panel to be that independent scrutineer, the report was briefly on line then removed from the Department of Planning’s Major Projects web portal and the recommendation on geological faults conveniently ignored.

There is also a need for microbial testing.

A significant new report regarding the occurrence of methane (CH4) in groundwater, including the identification of production and migration pathways, has been published: “Constraining source attribution of methane in an alluvial aquifer with multiple recharge pathways”.

It is focussed on The Lower Namoi Alluvium (LNA), New South Wales, and states: “Failure to establish natural pathways of water and gas migration prior to gas development and groundwater extraction has resulted in considerable debate about the causes of high CH4 concentration within aquifers (Heilweil et al. 2015) and highlights the need for identification of baseline conditions and primary CH4 origin and migration pathways”.

Map of the study area indicating groundwater bore locations where samples were collected and major geological structures. The red bores are the locations of our groundwater samples; the blue wells are locations of gas wells.

We told in Part 1 how aquifer interference has already occurred in the Pilliga due to historic fracking by Eastern Star Gas and their contractors. We also need to consider the cumulative impact of gas mining in tandem with Narrabri Underground, a large long wall underground coal mine which is immediately contiguous to the east. Combined with the abandonment of the NCRAT, the tardiness around baseline implementation and secrecy surrounding geological faults, local seismic activity and the Water Expert Panel recommendations, this all seems like a perfect storm of conditions for major catastrophic groundwater damage.

All government documents quoted in this article can be accessed here

All images here

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