ARRISCAR – Initial Gap Analysis of Safety Risk Assessment in EIS

Santos Risky Business – Risk assessment document that was removed from the NSW Major Projects site detailing risks to public safety which the NGP EIS has failed to address. According to the document there are still 14 OPEN observations including:

• The hazards and risks associated with the existing wells, including their “conversion or upgrade”, do not appear to have been included in the PHA.
• No explosion overpressure analysis was performed at the wellheads as it is assumed the area is open and there is insufficient confinement and congestion to result in an explosion.
• The PHA has not demonstrated that the cumulative risk of initiating a
  bush fire from the proposed 850+ wells and associated gas gathering and processing facilities is low relative to the background risk and compliant with the Department’s criteria for the protection of the biophysical environment.
• The hazard register does not appear to include hazards and risks from
  blowouts during the drilling phase.
• The hazard register does not appear to include hazards and risks associated with the power generation plant at Leewood. Other activities (e.g. pig launch and recovery) are also omitted.
• The hazard register does not appear to include hazards and risks due to the presence of other infrastructure within the pipeline corridor (i.e. It is understood that the new medium pressure gas pipeline (864mm diameter) will be in a corridor that already contains an existing 257mm diameter gas pipeline flowing from Bibblewindi to Wilga Park Power Station and will contain a new 132kV power transmission cable). These should be included in the PHA (As per Section 4.1 of HIPAP No. 6).

Scope of Review
The Secretary’s Environmental Assessment Requirements (SEARs) for the NGP require that the Environmental Impact Statement (EIS) address Public Safety – including:
• an assessment of the likely risks to public safety, paying particular attention to potential bushfire risks, the potential for gas leaks, the transport, handling and use of any dangerous goods;
• a Preliminary Hazard Analysis (PHA) in accordance with Hazardous Industry Planning Advisory Paper (HIPAP) No. 6 ‐ Guidelines for Hazard Analysis (DPE, 2011); and
• consideration of appropriate setbacks and/or asset protection zones for well heads, gas processing facilities and other infrastructure to manage risks.
The scope of this independent review was limited to these requirements, which are addressed in Chapter 25 and Appendix S of the NGP EIS. Safety aspects not covered by HIPAP No. 6 (e.g. Including health risks from fugitive emissions, dam safety, etc.) were excluded from this review.
The land use safety planning risk criteria referred to in HIPAP No. 6 (And described in more detail in HIPAP No. 4 – Risk Criteria for Land Use Safety Planning) may be relevant to the consideration of setbacks and/or asset protection zones. Therefore, these considerations were included in this review.