Sept & Oct | 2019
EPA NCCC Newsletter

The following is a monthly update for the Narrabri Community Consultative Committee (CCC) 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 2019
Inspections undertaken by EPA – October 2019
EPA site inspection map - October 2019

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Investigations

Background

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.

Regulatory activity

Nil.

Running log

Old investigations PEL 238, PAL2 and PPL 3 outcomes

Incident	Outcome
October 2018 Irrigation at the Leewood Facility. 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 ceased irrigation at Leewood and no environmental harm was identified.
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.

Inspections undertaken by the EPA - Sept 2019

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

Inspections undertaken by the EPA - Oct 2019

Site ID	Date Inspected	Reason	Action / Outcome	Status	Relevant statutory document
Tintsfield Pond 1	01/10/2019	General inspection	No issues identified	Active	EPL 20350
Tintsfield Pond 2	01/10/2019	General inspection	No issues identified	Out of service/ Inactive	EPL 20350
Leewood Pond 1	16/10/2019	General inspection	No issues identified	Active	EPL 20350
Tintsfield Pond 2	16/10/2019	General inspection	No issues identified	Out of service/ Inactive	EPL 20350

Site inspection map

EPA site inspections undertaken at Narrabri - October 2019

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Every effort has been made to ensure that the information in this document is accurate at the time of publication. However, as appropriate, readers should obtain independent advice before making any decision based on this information