Name Address (line 1) Address (line 2) State, Postcode

Date

The Chief Executive Attention: The EIS Coordinator (Surat Gas Project) Statewide Environmental Assessments Department of Environment and Resource Management GPO Box 2454 Level 8, 400 George Street BRISBANE QLD 4001 or by email to eis@derm.qld.gov.au.

Arrow Energy Surat Gas Project EISSubmissions close Thursday, 14 June 2012

To whom it may concern, Please accept my submission on Arrow Energies Environmental Impact Statement for their proposed Surat Gas Project, (related to mining Coal Seam gas in the Surat Basin).Below are my comments Arrow Energies proposed coal seam gas wells will produce (according to their EIS- Environmental Impact Statement) would result in an unacceptable level of major negative consequences for the environment and communities across the region. Below are some of the failings of Arrow Energies Proposal as it relates to Ipswich, the Lockyer Valley and the Bremer river and local acquifers. Below I will be making the case that the EIS is incomplete and does not address the impacts of brine management - the EIS (Chapter 26 Waste Management) simply presents a discussion paper prepared by Coffey Environments with no clear indication of what option is intended to be used.

Brine production and storage 1

The EIS clearly states that Brine is a significant by-product of the water treatment process, which also

requires specific measures to manage its storage, use and/or disposal. Assuming an average salt concentration of 4,500 mg/L, Arrow expects that treatment of coal seam gas water will generate in the order of 4.5 t of salt per megalitre of coal seam gas water. Arrow will continue to monitor coal seam gas water quality as the development progresses; however, development is planned with the assumption that similar water quality and salt concentrations will be observed across the entire project development area. [This works out to approximately 770 Gigalitres of water from coal seams with this water containing 3.5 million tonnes of salt] Figure 5.17 displays the brine management options and the expected average and peak annual volumes of salt production. Although beneficial use is the preferred option for brine management, for the purposes of this impact assessment it is assumed that brine will be stored in dams and disposed to a suitably licenced landfill.
The EIS offers a number of OPTIONS- of which the below have been highlighted:

a. Ocean Outfall
Disposal of brine to the sea via an ocean outfall pipeline is a feasible option that is being investigated by Arrow. As with coal seam gas water the viability of an ocean outfall will be evaluated at the time of detailed design of the field and facilities. Concerns/Objections: a) Where is the pipeline to go? b) What it the proposed route? c) What is the environmental impact from the pipeline (including Flora and Fauna)? d) What is the social impact from this? e) What are the proposed off-sets of any damage caused? f) What is the evidence that the outfall of the pipeline will not cause a localized increase in salinity within the area of the plume? As Arrow does notspecify where this outfall is likely to be we can not judge the environmental impact of this on Moreton Bay

b. Suitably Licenced Landfill

An assessment of waste disposal facilities indicates that suitably licenced facilities exist in the region. It is assumed that other commercial operations will be developed to capitalise on this waste stream. Arrow will develop appropriate storage capacity to manage brine until such time as permanent disposal solutions are operational. The closest currently available suitably licenced waste disposal facility is located at Swanbank, near Ipswich. This EIS has assumed that all brine concentrate will be trucked to Swanbank. Concerns/Objections:

a) Where is this waste disposal facility located at Swanbank? b) Is this currently licensed to handle brine? c) What method is being used to store this brine?-ie the EIS does not specify whether this brine is going into dams for evaporation or how the end product ie the salt is then to be stored or disposed of?? d) What is the name of the company/facility at Swanbank how is Arrow allowed to transfer responsibility of the waste product to another company (if it is)? In which case if it is not the EIS is incomplete and does not address the impacts of brine management as it is not an option for Arrow to transfer the responsibility for brine management to another entity according to the Environmental Management guideline. e) Are those dams (if this method is being used) subject to overland flow? Is water from these dams likely to end up in the Bremer river via Bundamba Creek (or Six Mile Creek depending on the location)? f) How much water/brine is expected to leak into local aquifers or Bundamba Creek and then the Bremer River and what is the likely environmental impact?

c. Transport via Trucks to- Suitably Licenced Landfill

The Traffic Management Study presented in Chapter 16 of the EIS does not consider the impacts of the trucking of brine from the well fields at all. Concerns/Objections:

a) The EIS specifies local truck movement around the Darling Downs where the mining
is occurring but is sadly lacking in any detail on how the brine from the coal seam gas wells in the Surat Basin is to travel to the preferred suitably licenced landfill site at Swanbank.

b) The estimated truck movements from this transport have been worked out as - from
my calcs on the waste chart 5.17, if there is an average of 200,000 t/a of Brine waste to suitable licensed landfill that would equate to 5000 x 40t B doubles / annum or on average 13 return trips per day x 365 days / annum. c) What route will this truck movement going to take? No roads are specified in the EMS. d) What damage will this do to the local roads involved? e) How will noise, dust and increased traffic affect the local community and its environs (environment- include the local Fauna)? f) Although it is sheer supposition to link these truck movements to the new proposed Toowoomba Range Road- Is this the route the trucks will take? What is the cost of this new infrastructure to the community?

d. Further Comments/Concerns
3

Salt or brine disposal is regulated under the Environment Protection (Waste Management) Regulation under EP Act (EA). There several key sections that apply. -A requirement for a Coal seam gas water management plan (including brine management plan). ( I note that the gas water management plan has not been released as a public document but is referred to in the EIS.)Regulated waste management and tracking system - No encapsulation of brine dams on site. (This regulation is only about a year and a half old and prevents the mining companies having evaporation ponds in the mining area because of agricultural values or where there is a potential to release into water courses used for a drinking water supply. Most of them have a town downstream and the rules allow the company to make a claim that there is no material impact on a drinking water supply but Arrow has just stated this is not possible in the EIS. They are clearly not considering that as an option as the cumulative impact over time from the increasing number of wells would rule that out anyway. (During the heavy rain and floods last year a large number of the existing ponds magically emptied themselves. DERM is currently prosecuting about three of these cases) - Regulated waste management facility and commercial agreement with regulated waste service provider. But, using a regulated waste management facility only applies to salt disposal, not brine evaporation or injection. There are a number of fact sheets on the DERM Web site which give a summary of the regulations in place in regards to brine management. This one: Salt and brine management in coal seam gas production http://www.derm.qld.gov.au/factsheets/pdf/environment/en9.pdf states that salt (not including brine) may be:- directed into a purpose built licensed regulated waste disposal facility on freehold land owned by the CSG operator. The CSG operator can only locate purpose-built facilities on land they own. If salt is to be disposed of in this way, the CSG operator must ensure that the footprint and the number of any purpose-built facilities is minimised.-disposed of in a licensed regulated waste disposal facility. These facilities will be listed as contaminated sites and recorded on a register as they will require ongoing management action by the CSG operator. CSG operators will be held responsible for these disposal sites and will need to remediate them before they are allowed to surrender the petroleum tenure. The guideline that sets the criteria for a CSG company to address in their Environmental Management Plan Preparing an EM Plan for CSG activities http://www.derm.qld.gov.au/environmental_management/land/documents/csg-environmentalmanagement-plan.pdf lists a heirarchy of management options: 1) Injection of brine if the target formation 2) Waste reuse/recycling through chemically processing / treating brine or salt residues to create useable/ saleable products such as soda ash; 3) Waste disposal through: (i) disposal of brine to an ocean/estuarine environment; then (ii) disposal of salt into an existing licensed regulated waste disposal facility (If salt is to be stored it must be in a landfill monocell facility) ; then (iii) disposal of salt into a purpose built regulated waste disposal facility (landfill mono cell) on freehold land owned by the P&G tenure holder.

Further objection: The EM Plan must include an analysis providing information sufficient to justify the management options chosen, and where higher management options in the hierarchy are not chosen, provide information sufficient to demonstrate they are not feasible because of, for example,

environmental, technical, economic, legislative or social considerations. The EIS contains is no discussion of the hierarchy, just statements that the brine is going to a licensed waste disposal facility, although there may be an accompanying document ( the EM Plan) that is not publically released. From knowledge gleaned during research for this submission it appears Arrow is not legally allowed to send brine to an existing waste disposal facility- nor are they allowed to construct evaporation ponds in the gas fields area. So they must consider the evaporation of the brine to salt (somewhere where this is allowed) or injection of the brine (on land they own). Arrow has two options: have the brine injected or evaporate to salt. In either case they appear to be responsible for the management of the issues involved. If they go to injection, the same guideline says: The salinity of brine may be higher than the salinity of the native groundwater in the target formation. However, the target formation for brine injection must: be a single geological unit that is not regionally consistent and extensive (which Arrow states in the EMS they have not yet found such); or be isolated above and below by an aquitard or aquicludes within the hydraulic impact zone; and not be an aquifer that does or could supply water for potable, agricultural, industrial and commercial purposes. A key objective for the assessment of an injection proposal is to ascertain that there is no or minimal risk to the environment values and the groundwater resource associated with the aquifer or geological formation where fluid is proposed to be injected. Therefore the key component to include in an application for injection is to prepare a risk assessment providing details on potential hazards including their inherent risk, preventative measures and the residual risk. The point here is that Arrow must make the case, not simply refer to an existing licensed waste facility. Based on the above comments I contend that the Precautionary Principle should be applied and that the present proposal places an unacceptable risk to the community, its infrastructure and the environment including Flora and Fauna, and accordingly should be rejected.

Yours sincerely,

Please remember the EIS must be in by the 14th of June 2012- to the Chief Executiveasper address above. To make sure the message gets through loud and clear you can cc the Queensland Minister for Environment and Heritage Protection Andrew Powell - info@ehp.qld.gov.au, glass.house@parliament.qld.gov.au and the Federal environment minister - and Tony Burke: environment@ministerial.qld.gov.au, Tony.Burke.MP@aph.gov.au Especially with a Federal Election coming up and a major Landcare Conference to be held at the Brisbane Convention and Exhibition Centre on the 28-30 June 2012- this may have some impactsee http://qldlandcareconference.org.au/speakers.php Other e-mail addresses you may wish to send your concerns/submission to; The member for LockyerIan Rickuss Lockyer Electorate Office <LOCKYER@parliament.qld.gov.au>, The member for Ipswich WestSean Choat <Ipswich.West@parliament.qld.gov.au>, The Mayor for LockyerMayor of Lockyer Cr Steve Jones <sjones@lvrc.qld.gov.au>, The Mayor for Ipswich"Mayor for Ipswich Paul Pisasale" <PPisasale@ipswich.qld.gov.au>, The Councillor for Division 10"David Pahlke" <dpahlke@ipswich.qld.gov.au>,

OR If you have time to write your own submission The relevant Arrow Energy website is http://www.arrowenergy.com.au/page/Community/Project_Assessment_EIS/Surat_Gas_Project_EIS/ And for the EIS itself- E Book link http://www.qikpress.com.au/Volume-1---EIS/6015cc98-ad42-4f56-9fdb-9fa400b47867

The chief executive will accept all properly made submissions and may accept written submissions even if they are not properly made. A properly made submission is one that:

is written

is signed by or for each person who made the submission states the name and address of each signatory is made to the chief executive is received on or before the last day of the submission period

For further information regarding the EIS process for this proposal, contact the EIS coordinator by calling 13 GOV (13 74 68) or emailing eis@derm.qld.gov.au.