NCCC newsletter September/October 2018
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September & October | 2018

EPA NCCC Newsletter

The following is a monthly update for the Narrabri Community Consultative Committee (NCCC) regarding activities undertaken by the NSW Environment Protection Authority (EPA) relating to PEL 238, PAL 2 and PPL 3 (Narrabri Gas Project).
It includes activities relating to the regulation of Environment Protection Licence (EPL) 20350 and the EPA’s functions conducted under the NSW Gas Plan.
Attachments to this month’s update:                                              

  • Running Log – Old Investigations of PEL 238 Outcomes
  • Inspections undertaken by EPA – September 2018
  • EPA Site Inspection Map – September 2018
  • Inspections undertaken by EPA - October 2018

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On 19 February 2013 the EPA became responsible for investigating environmental incidents that occur during coal seam gas activities under the provisions of the Protection of the Environment Operations Act 1997 (POEO) and issuing Environment Protection Licences (EPL) for coal seam gas activities.
On 1 July 2015 the EPA commenced a new role as the lead regulator for compliance with, and enforcement of, conditions of approval for gas activities in NSW. This includes regulating consent conditions and activity approvals issued by other agencies (excluding work health and safety). In carrying out this role the EPA works with the relevant experts and NSW Government agencies.
Gas activities must comply with a broad range of regulatory controls, including Acts, regulations, codes of practice, titles, approvals and other controls.
The prioritisation of investigations is determined using a risk assessment for investigations that considers the level of environmental impact and the likelihood of environmental harm occurring.

Current investigations

On 12 October 2018 the EPA issued Santos with a Penalty Notice for an alleged breach of s.91A(2) of the Water Management Act 2000 for the offence of 'using water without, or otherwise than as authorised by, a water use approval'. Santos have ceased irrigation at Leewood following discussions with the EPA, with no evidence of environmental harm identified. 

Running log

Old investigations PEL 238, PAL2 and PPL 3 outcomes

Incident Outcome
February 2018
Crop Health at the Leewood Facility
The EPA investigated the Leewood facility following a community complaint on 9 February 2018 that raised concern about the alleged poor condition of the Lucerne crop being irrigated at the Leewood facility.
EPA officers inspected the Leewood facility on 12 February 2018, and reported that the irrigated crop appeared to be healthy and relatively uniform across the irrigated area. The matter was finalised, as no environmental harm was identified from the inspection that warranted further investigation.  The EPA advised the complainant of the outcome of the inspection.
December 2017
Crop Health at the Leewood Facility
A community complaint was received on 27 November 2017 regarding alleged poor condition of the crop being irrigated at the Leewood facility and concerns about the high level of water in one of the Leewood Ponds. NSW EPA officers attended the Leewood facility on the 15 December 2017 to check the irrigated crop, and were satisfied that the growth of the irrigated crop appeared to be healthy and was relatively uniform across the irrigated area. An inspection was also undertaken at the Leewood Ponds on the same day, and EPA officers confirmed the produced water levels were within operating capacity. Water levels in the ponds can often fluctuate dependent on several factors including the weather, water treatment at the Reverse Osmosis Plant and the irrigation activities taking place at the time.
Following the inspections at the irrigated crop and produced water ponds, the EPA were satisfied that the crop was in good health and observed no environmental concerns during the inspection that would warrant further investigation. The EPA advised the complainant of the outcome of the inspection.
August 2017
Crop Health at the Leewood Facility
The EPA is liaising with Crown Lands and Water on a matter raised with the EPA relating to approvals required by Santos for the irrigation activity at the Narrabri Gas Field. Multiple approvals and licences are currently in place for the irrigation activity including an Environment Protection Licence.
The results from the initial round of monitoring, as required by the Environment Protection Licence, has been submitted to the EPA. The EPA has reviewed the data and confirmed that the irrigation water meets the monitoring requirements of this Licence.
June 2017
Bohena 13C and Bohena South 2C (PAL 2)
The EPA undertook a review of Bohena 13C and Bohena South 2C following the submission of ESF2 rehabilitation relinquishment documents from Santos. The EPA undertook unaccompanied inspections of the sites, and followed up on some matters with Santos regarding the rehabilitation status of the sites.
A community call to the EPA Environment Line was also lodged with regards to Bohena 13C.
EPA officers re-inspected both sites. No environmental harm was identified from the inspections, with the matters finalised and no further action considered necessary.  
The EPA also sent a response letter to the complainant advising the outcome and finalisation of the matter at Bohena 13C.
February 2017
Groundwater pH levels at Dewhurst 14C (EPL 20350)
The EPA investigated data from groundwater monitoring bore, Dewhurst 14C, following an Environment Line call on 17 February 2017 that raised concern about data published on the Santos Water Portal, showing alkaline results (pH>9.5) for water samples collected from monitoring well Dewhurst 14C.
An EPA investigation showed the findings indicated the alkaline pH reported for Dewhurst 14C was the result of local geological and groundwater conditions, and that there was no evidence that the groundwater chemistry in Dewhurst 14C had been modified because of water pollution.
The investigation has been finalised, with no issues identified.
February 2017
Tintsfield Flare Incident (PEL 238)
On 24 February 2017, the EPA were notified by Santos of an incident relating to unauthorised access to Wilga Park, resulting in damage to the Tintsfield Flare.
Investigation confirmed that the gas pipe had not been ruptured and there was no environmental harm.
The EPA has concluded its investigation.
December 2016
Leewood Northern Sediment Dam
EPA Officers Investigated Leewood Northern Sediment Dam following an Environment Line call alleging an overflow incident from Leewood Ponds Water Treatment Facility.
Incident was investigated and samples taken, with lab results confirming no BTEX present and the materials classed as organic; dried sun bleached algae; and a naturally occurring protozoa. Investigation finalised, with no issues identified.
November 2016
Bohena Creek
Report alleging that Bohena Creek was impacted by the Bibblewindi Water Treatment Plant and gas wells.
EPA officers visited the area of Bohena Creek that the reporter referenced. There was no evidence that environmental harm has occurred.
September 2016
Leewood (PAL002)
Report alleging Leewood produced water dams were overflowing.
The EPA officers visited the site and all ponds were observed to be operating with adequate freeboard. There was no evidence of any overflow or spill from the ponds.
September 2016
Bohena 2
Report alleging Santos were using produced water from Leewood for watering program at Bohena 2 salinity site.
Environment Line complaint alleging Santos were using produced water from Leewood for the watering program at Bohena 2 salinity site following a Namoi Waste truck seen leaving Leewood and heading to Bohena 2 salinity site. EPA Officers attended the site, investigated and took water samples. Lab results indicate that the source of water is not consistent with produced water.
The EPA sent a response letter to complainant advising this.
April 2016
Bohena Creek Road
Methanol Drum on road.
Santos staff located a 44 gallon drum labelled ‘Methanol’ dumped on Bohena Creek Road near the Leewood Water Treatment Facility. Police and HAZMAT attended and secured the item. 
The drum was not on the Santos site, nor related to its activities as per media Tweet by the EPA.
March 2016
Leewood Pond
Alleged leaking.
EPA officer inspected storage ponds and met with Santos staff. No evidence that produced water was leaking.
No further action was required. 
March 2016
Bohena Creek Road
Report that a vent had been left open, unattended and emitting methane gas.
Santos has approval to vent gas from high and low point vents along the water gathering lines for safety and operational purposes – this is performed manually by a field operator.
Santos has amended the manual venting operating procedure. The procedure clearly notes that a high point vent is not operated without an operator present.
March 2016
Santos Pilliga
Report received that there was a ‘foamy residue’ left along Beehive Road.
The complainant returned to the site some days later with a Geiger counter and recorded a reading allegedly linked to the high and low point vents.
An EPA Officer spoke to the complainant who advised that the location they took the Geiger counter reading was a few kilometres away from the area of concern and there was no evidence to support the initial claim.
No further action required.
March 2016
Leewood Water Treatment Facility
Report alleging a truck was spraying produced water between the internal fence and the property boundary fence for dust mitigation.
An EPA Officer viewed available data confirming raw water from an on-site bore was used for dust suppression at the time of the allegation. The EPA supports dust suppression which is a requirement of the Santos EPL. 
No further action required as at 15 March 2016.
February 2016
Santos Pilliga
Report of 35,000 litre spill at unmanned Santos facility.
Investigations proved minor water run off with no environmental or health risks.
Media release: Water Run-off From Leewood Water Treatment Facility in Narrabri Cleaned Up
January 2016
Leewood Water Treatment Facility
Alleged discharge of sediment laden water.
The rain water discharge followed heavy rain. Santos undertook immediate works to prevent further discharge from the site installing coir mats and construction of bunding.
The EPA inspected site and determined no environmental harm had occurred and that no regulatory action was required.
January 2016
Santos Pilliga
Report a ‘foamy caramel coloured’ material on the roadside near operation site.
The EPA inspected the site and collected samples. Analysis determined it was a natural event, likely due to the decomposition of organic material. 
No further action was required. 
September 2015
Bohena Creek
Piezometer located in creek.
No regulatory action required.
January 2015
Santos Dewhurst Southern
Water flow line.
No breach of EPL 20350 identified.
Santos varied operational practices for high point vents following negotiations with the EPA.
Media release: No environmental harm but improvements needed
February 2014
Namoi Waste
Storage of Santos drilling mud onsite.
6 May 2014
The EPA issued Namoi Waste Corp with a Penalty Notice for breach of s145 of the POEO Act.
Note - The Penalty Notice issued was not related to the original compliant regarding waste from coal seam gas, rather other waste material identified during the course of the investigation.  
Media release: EPA issues Naracor and Namoi Wastecorp with penalty notices for unlawful waste transport and storage
March 2013
Bibblewindi Water Treatment Facility
Pond liner failure.
11 Feb 2014
The EPA issued a Penalty Notice for s120 Pollution of Waters.
A Pollution Reduction Program (PRP) was added to EPL 20350 (Environment Protection Licence) requiring the development of a Remediation and Monitoring Plan and the implementation of this plan.
March 2013
Tintsfield Ponds
Detection of elevated levels salinity and metals.
Insufficient evidence to determine if the changes detected in groundwater were the result of leaks from the Tintsfield ponds or were from natural factors. A PRP was added to EPL 20350.
Media release: No environmental harm but improvements needed

Inspections undertaken by the EPA - September 2018

Site ID
Date Inspected
Action / Outcome
Relevant statutory document
Dewhurst 23 4/09/2018 General inspection Ongoing Shut-in PEL 238
Dewhurst 25 4/09/2018 General inspection Ongoing Shut-in PEL 238
Dewhurst 27 4/09/2018 General inspection Ongoing Active PEL 238
Dewhurst 29 4/09/2018 General inspection Ongoing Active PEL 238

Site inspection map

EPA site inspections undertaken at Narrabri - September 2018

Inspections undertaken by the EPA - October 2018

Site ID
Date Inspected
Action / Outcome
Relevant statutory document
Nil Nil Nil Nil Nil Nil

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