Santos recently submitted their Supplementary Response to Agency Submissions (SRTS) to the NSW Government. The document took over 12 months to formulate but flat out refuses to address several major requests by government agencies.
NSW Planning released the document the day before the Santos AGM held in May and since then CEO Kevin Gallagher has been shamelessly pressuring the NSW government to expedite the assessment process despite Santos being the ones who’ve dragged the process out for many years.
The pressure is being applied by Santos, some industry groups, the Australian Workers Union (who have recently benefitted from hearing the other side of the story), Federal Resources Minister Matt Canavan and now ACCC Chair Rod Sims.
Have Santos overstepped? We believe so.
Industry cheerleader Matt Canavan admits here that the industry made mistakes in Queensland, he thinks NSW should “get on with the gas”. Canavan will find that NSW are not so keen to make those same mistakes, hence the need for detailed risk assessment and thorough evaluation of the key issues such as waste management.
The cover of the SRTS features a Santos employee posing in front of a coal seam gas well with a sheaf of wheat freshly plucked from a field that is unlikely to have been irrigated by coal seam gas waste. The same employee featured in an advertisement for the company that was pulled from TV in 2012 due to concerns about it’s legitimacy. The cover is at odds with the blatant disdain and arrogance-sprinkled contents which decline the NSW Government request for more information on many aspects of the project.
Over the course of the assessment process (dating back to February 2017) Santos have submitted three documents to NSW Planning to support their proposal. Thousands of pages later they still have not addressed several aspects of waste management that absolutely must be considered as significant environmental risks and should be addressed for “world’s best practice regulations” to be kept to.
Santos state on page 28-1 of Chapter 28 of their Environmental Impact Statement (EIS) for the Narrabri gas Project:
Santos’ own document states this fact and common sense then directs that all identified risks need to be fully assessed. Is it that the risks we are about to detail are deliberately ignored because assessing them would leave no doubt that the project can not be conducted safely with minimal environmental risk?
Corrosion and Bacteria
A concerning article was published earlier in the year, the article has now been removed from the internet but can be accessed here – detailing an innovative solution to a corrosion issue which impacts gas production and the integrity of well casing. Charles Albouy, Schlumberger, was quoted, “Microbiologically-influenced corrosion seems to be systemic in the region, and other operators might encounter similar issues in their CSG wells.” He was referring to the Surat Basin of which the Pilliga is a part. Corrosion has been noted on the exterior of some Santos wells in the Pilliga forest.
It’s not just corrosion caused by microbial activity that hasn’t been addressed by Santos for it’s proposed Narrabri Gas Project. Microbial/bacterial activity in streams and waterways is a documented issue for waterways in the US that have proximity to Unconventional Gas Operations.
Santos tell us in their EIS that they will use a process known as “Managed Release”, whereby they will release to Bohena Creek their treated waste. Have any studies been done on the microbial/bacterial impact of this method of waste disposal?
Santos propose to release 9.5 megalitres (Ml) per day into Bohena Creek when the flow of the creek is greater than 100Ml a day. An Olympic sized swimming pool holds 2.5Ml of water. Bacteria and microbial activity is not mentioned is Chapter 12 Surface Water Quality of the EIS which deals with the managed release of treated water and other beneficial reuse ‘solutions’ and only mentioned 3 times in Appendix G1, Bohena Creek Managed Release Study, none of the three mentions relate to the bacterial/microbial load of the treated water.
It is doubtful that the treated waste will be free of bacteria and microbial activity.
The Agency charged with protecting the environment from harm and the lead regulator of the gas industry in NSW is the EPA. The NSW EPA lodged its submission to the Environmental Impact Statement (EIS) here. Numerous requests were made for more detail particularly around the waste issues.
Briefly, Santos refused:
- EPA request on an assessment of the capacity and capability of landfills located within 200km of the project to take the quantities and types of waste proposed to to be generated by the project;
- to fully describe the mix, turn bury method used for drill cuttings and the request for ongoing monitoring of this material;
- EPA’s recommendations about site specific soil surveys and ongoing soil monitoring when employing irrigation to dispose of their waste;
- EPA’s request for monitoring and trigger systems to watch for toxicity in Bohena Creek as a result of treated water discharge;
- EPA’s request for further information to inform assessment of fugitive methane, Volatile Organic Compounds (VOC’s) and air toxics, including project specific gas composition data (particularly around C02) and demonstration that their leak detection and repair program adequately minimises potential for fugitive methane and VOCs.
The deeper you look into the EIS the more the holes become obvious.
Biocides are substances that control bacteria and other harmful organisms, they inhibit growth of sulfate-reducing bacteria and are essential to both the continued production of the resource and treatment of the waste. Worldwide the regulatory process to authorise and permit the use of a biocidal product can be complex, lengthy and expensive but not in NSW.
As yet, we do not know what type of biocide will be chosen and Santos are not required to go though any assessment/testing process to prove safety and efficacy. Overseas, it is different: “To determine a suitable site-specific biocide (combination), 6-log reductions or greater in SRB, APB, or other deleterious bacterial populations are typically aimed for in preliminary laboratory testing according to NACE Standard.
Will Santos employ
this kind of rigour to its’ biocide selection?
Many biocides are short-lived or degradable through abiotic and biotic processes, but some may transform into more toxic or persistent compounds. The EPA recommends, that should the project be approved, a condition of consent to monitor the mixing zones in Bohena Creek upon commissioning to validate model predictions and also to assess the combined impacts of different chemicals in the discharge water. p33:
Santos denies this request.
The denial of requests from Government Agencies is a familiar theme throughout the Supplementary Response to Submissions and does not bode well for the receiving environment.
Denial of serious issues and events seems normal for Santos?
On the 14th April, 2016 an incident occurred on the corner of Old Mill Road adjacent to the Santos Leewood facility. A drum of Methanol UN1230 was recovered from the road by the Hazardous Materials Unit and the Narrabri Fire Rescue. Police and Ambulance were also in attendance. The accident caused a full scale response and had the potential to be deadly.
An eyewitness to the accident said the drum left the back of a truck as it rounded the corner. Santos denied this incident involved them despite Santos security staff and vehicles being present during the entire incident.
This constant denial, blocking of information and outright refusal to provide information when asked is an ongoing problem for community members tasked with informing the community of Santos’ operations. The community representative at the CCC, Mr Tony Pickard, has indicated recently that Santos is taking months to answer simple questions. For instance, Santos won’t reveal to community where the first and only cut of lucerne from Leewood was taken.
Santos seems to be totally disregarding the fact that they do not currently have approval to irrigate with their treated waste. The EPA fined Santos the minor amount of $1,500 for not having a Water Use Approval in 2018 and Santos still do not have a Water Use Approval. They will “not be permitted to recommence irrigation until they have obtained the approval” According to the EPA. It’s misleading that Santos indicate they have consent in the SRTS when they do not. (p 2-23)
Toxic waste disposal
One of the major issues surrounding the project is how Santos plan to deal with the predicted 35 billion litres of wastewater including toxic salts wastes, brine and crystallised salt that the project would produce over it’s operational life.
Dr Matthew Currell, a Senior Lecturer and Program Manager (Environmental Engineering) at the School of Engineering, RMIT University says of the brine in his Review of Santos Narrabri Gas Project Response to EIS Submissions “The brine produced from the Leewood facility will be a hazardous material, enriched in the chemical elements that occur in the produced water.” He also notes “Santos has underestimated the volume of waste salts that will be produced by its water treatment plant by 50% or more.”
Santos has still not identified a suitable facility that would accept the volume of waste prescribed in the EIS despite having numerous submissions to their EIS expressing concern about this issue. A total of 19,485 submissions raised concerns about waste management (Santos Rts Narrabri Gas Project – Response to Submissions – Report Part A.pdf page 3-10).
Santos say in Chapter 28 of their EIS, p10 28.3.2 that regional facilities have limited capacity for additional waste.
Have Santos contacted any of the waste facilities within their 200km radius?
Local landfills do not appear to have the capacity to accept the volumes of waste that the project will produce. The EPA were quite specific in their request for Santos to provide more information and detail around this issue but Santos have refused.
The EPA requests that the Department of Planning and Environment require an assessment of salt disposal options at different scales, including an assessment of the capacity and capability of landfills located within 200 kilometres of the project to:
- take the quantities and types of waste proposed to be generated by the project
- An assessment of the capacity and capability of landfills at a regional scale to take quantities and
- types of waste proposed to be generated by the project
- An outline of contingencies.
Santos has refused this request instead comparing their (reportedly underestimated) volumes of waste to the Murray Darling Basin Salt Reclamation Scheme (MDBSRS) which is a completely different type of salt and if you go back to Dr. Currell’s statement that the brine will be a hazardous waste and then cast your eye over the latest Santos document you will observe that Santos seriously downplay the toxic nature of the waste by comparing it to the MDBSRS.
Naturally Occurring Radioactive Materials (NORMs)
Will the yet to be seen Waste Management Plan describe a testing regime for NORMs?
Santos acknowledge in their Response to Submission (p. 6-267) that submissions mention NORMs in relation to drill cuttings but then do not address their occurrence. There is no mention of the possible occurrence of NORMs in pipework, sludge or elsewhere.
The EPA’s own water quality unit recommended Santos monitor ground water for “radionuclides”, which include thorium, radon and radium. Strontium has been measured in Santos’ gas operations at somewhat concerning levels and strontium concentrations can be high in the Surat Basin (34:31). “Things like strontium are actually very common through the Bowen & Surat Basins” Ben Kele, Arris Water.
As wells get older they are more likely to contain higher concentrations of contaminants. This needs to be taken into account as there are older wells in the Pilliga which have been heavily fracked in the past.
Strontium is detailed in the Leewood REF Produced Water Quality Parameters at 24.6 mg/L but in the newer EIS it is presented as being at much lower levels (p. 42 Appendix T2 Health impact assessment.pdf) between 1.18 and 4.15 mg/L. Inconsistencies throughout Santos documentation are rife.
Meanwhile, well respected Nuclear Radiation Scientist Dr Ian Fairlie details in this presentation why we should all be concerned about the risks posed by radiation for gas mining. His advice is below.
Piecemeal assessments, continuous modifications to licences combined with high staff turnover of key senior scientific and management positions have led to a dog’s breakfast of documentation that takes way too long to absorb and assess.
Northwest Protection Advocacy calls on the agencies and government to stand firm in their requests for standard information that needs to be provided by the proponent Santos to fully inform of the dangers and risks inherent to the project. Further, we outright reject interstate and corporate interference in the NSW assessment process by CEOs and Federal Ministers.