Peat Coal Seam Gas Water Management Plan MANAGEMENT PLAN · Peat Coal Seam Gas Water Management Plan MANAGEMENT PLAN Doc Ref: Q-8100-15-RP-0002 Revision: 4 Page 4 of 74 Australia

Peat Coal Seam Gas Water Management Plan MANAGEMENT PLAN

Doc Ref: Q-8100-15-RP-0002 Revision: 4 Page 2 of 74

Australia Pacific LNG Upstream Phase 1

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Executive Summary This coal seam gas (CSG) water management plan (CWMP) describes how water produced from CSG wells

in the Peat development area (petroleum lease 101) is managed safely and in a manner that is consistent

with the Queensland Government’s CSG Water Management Policy (DEHP 2012a), ensuring the protection

of environmental values (EVs) whilst balancing social and economic factors. It has been prepared to meet

Condition (D1), (D2), (D8) and (D9) of environmental authority EPPG00653413 (the Peat EA) and to

support an application to amend Condition (D3) and to add a new Condition (D16) as follows:

Existing Condition (D3):

The holder of this authority must ensure that any ponds used as a primary means of disposal of

associated water are decommissioned, remediated and the area rehabilitated to final land use

standard by 1 November 2011.

Proposed Amended Condition (D3):

Subject to Condition (D16), the holder of this authority must ensure that any ponds used as a primary

means of disposal of associated water are decommissioned by 1 November 2011.

Proposed New Condition (D16):

Despite Condition (D3) of this environmental authority, Peat GPF Pond 2 may be used as a primary

means of disposal of associated water.

The Peat development area covers approximately 24,000 ha of land in the Surat Basin of south central

Queensland between the towns of Wandoan, Taroom and Miles. Land use is dominated by grazing of

natural vegetation and local hydrology comprises ephemeral streams of the Dawson River sub-catchment.

CSG production in the Peat development area commenced in late 2000. The current rate of CSG water

production is low (around 0.02 ML/d) and, with no approved plans to expand CSG operations, is expected

to gradually decline over time. CSG water is currently gathered via buried pipelines to one (1) of five (5)

CSG water storage ponds; Gas Processing Facility (GPF) Pond 1, GPF Pond 2, Pond 12 Cell 1 and Cell 2,

and Pond 32. Where appropriate, and in accordance with the Peat EA, stored CSG water is used for

construction and dust suppression. The stored volume of water is also reduced by natural evaporation.

Development of a revised CSG water management strategy for the Peat development area addresses the

aforementioned conditions of the Peat EA and accounts for the field-specific characteristics of CSG water

production. A local needs analysis and performance evaluation of alternative CSG water management

options is presented in Table E-1.

Table E-1: Local Needs Analysis and Option Performance Evaluation

Option Assessment Outcomes

Priority 1 Options on DEHP Prioritisation Hierarchy (DEHP 2012a)

Municipal

water

supply

The predicted annual maximum CSG water production in the Peat development area equates to 2%

of the annual water requirements of Taroom, Wandoan or Miles.

CSG water would require treatment prior to supply, necessitating complex infrastructure with a

prohibitively high cost for supply for municipal use.

Infeasible on basis of inability to meet demand and extent of required infrastructure

Agricultural

use

There is only a very small area (15 ha) of irrigation within the development area, and it is located

23 km south of the Peat GPF.

There are four (4) feedlots within 15 km of the Peat GPF however CSG water production rates

could only be sufficient to meet the demand from one (1) of these feedlots and only for a limited

period (given that water production rates will decline over time).

Consultation with local landholders indicates they are unwilling to accept the predicted volumes

and qualities of CSG water available.

Infeasible on basis of inability to support long-term scheme, extent of required infrastructure

and lack of demand for available water quantity and quality from local landholders

Project

activities

CSG water could meet demand for dust suppression and construction in the development area.

Untreated CSG water could be used, subject to meeting water quality limits in Peat EA.

Taken forward due to potential of CSG water production to meet volume and quality demands





Option Assessment Outcomes

Industrial

use

The nearest potential industrial user is a coal mine which is located 85 km from the GPF.

However the water demand for this mine is met by an existing facility. Consideration was also

given to the possibility of supplying proposed coal mines in the region (none of which are

approved), but the maximum predicted rate of CSG water production is less than 1% of the

predicted daily demand for any one of these mines.

Infeasible on basis of distance from Peat GPF to industrial users

Injection to

aquifer

Prior treatment of CSG water would be required to avoid altering receiving water quality.

Given the predicted low volume and future decline of CSG water production, the construction of

the necessary infrastructure is considered to represent an uneconomic management option.

Infeasible on basis on extent of required infrastructure and environmental harm which would

occur if water was injected untreated.

Existing and

planned

beneficial

use

schemes

a) Beneficial use schemes in other Australia Pacific LNG development areas are operational but are

located in excess of 75 km from the Peat development area.

b) A treated CSG water pipeline is located within 10km of the GPF which flows to Glebe Weir.

Connection to this system would require the construction of a water treatment plant and

connecting pipeline

Option A taken forward as contingency option to be used as required

Option B considered infeasible due to the treatment infrastructure required

Release to

improve EVs

Untreated CSG water quality would cause degradation of receiving EVs if released.

Infeasible on basis of potential to cause environmental harm if untreated water released

Priority 2 Options on DEHP Prioritisation Hierarchy (DEHP 2012a)

Release to

watercourse

A water treatment plant would be required to produce water that would be suitable for release to

the nearest water course which is Roche Creek.

Discounted on basis of DEHP prioritisation hierarchy and the cost and extent of treatment

infrastructure required

Injection to

suitable

formation

Depending on receiving groundwater quality, target aquifer availability in the local area and

appropriate containment, it may be possible to inject untreated CSG water.

Given the predicted volumes of CSG water production, the construction of the necessary injection

infrastructure is considered to represent an uneconomic management option.

Infeasible on basis of DEHP prioritisation hierarchy and extent of required infrastructure

Evaporation

Climate characterised by net evaporation in all months. A proportion of stored water will

therefore evaporate under natural conditions.

Existing infrastructure can be used thereby minimising potential disturbance from new structures.

Taken forward as component of CSG water management scheme due to infeasibility of beneficial

use options with quality and quantity requirements commensurate with CSG water production

In addition to the local needs analysis and option performance evaluation, an assessment of the risks to

EVs associated with each option found that:

All options require trucking to transport CSG water between storage infrastructure within the

development area and minor upgrades which may be required to GPF Pond 2, which has a

minor impact to EVs (due to fuel consumption and emissions);

The evaporation option which involves the retention of GPF Pond 2 as an evaporation dam is

the only option to have a Low aggregate risk score. It incurs no additional risks to the EVs of

air, noise, waste or social/community. Low risks to the EVs of land and biodiversity, surface

water and groundwater are associated with the risk of seepage and overtopping of GPF Pond 2

and can be managed to acceptable levels by continued implementation of standard control

measures;

The option of using untreated CSG water to support Australia Pacific LNG Project activities is

considered to have a Medium risk, reflective of the need for additional truck movements. The

required transport distances (and therefore the associated emissions, risk of accidents and

social disturbances) are however considered manageable using existing controls;

The risks of using untreated CSG water for agricultural activities, aquifer injection, municipal

supply, industrial supply, release to surface waters or injection to a basement formation are





considered High or Severe and unacceptable reflecting the unsuitable nature of CSG water

quality as compared to relevant guideline criteria and a lack of suitable demand; and

The risks associated with all options that involve long-term treatment of CSG water by

Australia Pacific LNG are considered High and unacceptable, reflecting the need for regular

long-term truck movements to transport the water, either to the WTF or to a beneficial use

scheme, as well as land disturbance associated with installation of infrastructure.

On the basis of the assessments documented in this CWMP, the revised CSG water management strategy

for the Peat development area is as follows:

Aggregation of CSG water to a single, lined CSG water storage pond (GPF Pond 2);

Local beneficial use of stored CSG water to support construction and dust suppression;

Natural evaporation reflecting the regional climate; and

If required to manage unexpected CSG water production or extreme weather events that

cause the maximum operating level of storage infrastructure to be approached (as defined in

the structure’s operational plan), short-term trucking of CSG water for beneficial use in

another Australia Pacific LNG development area.

To transition the existing scheme to one which supports the revised CSG water management strategy,

Australia Pacific LNG will conduct the following activities:

Closed tank(s) will be installed at the site of Pond 12. Pond 12 and Pond 32 will be

decommissioned. The existing high density polyethylene (HDPE) pipelines connecting CSG

wells to this pond will be disconnected from the pond and reconnected to the closed tank(s).

CSG water previously gathered to Pond 32 will be gathered by the existing pipeline network to

the closed tank(s) at the site of Pond 12. GPF Pond 1 will be decommissioned and the HDPE

pipeline connected to GPF Pond 2;

Pond 12 Cell 1 and Cell 2, Pond 32 and GPF Pond 1 will be decommissioned and remediated in

accordance with a Transitional Environmental Program to be submitted to DEHP in 2015;

Regular vehicle movements will be established to truck CSG water from the closed tank(s) to

GPF Pond 2. The road on public land linking Pond 12 to the sealed public road will be

upgraded to allow for regular truck access;

The proposed CSG water management strategy is aligned to the CSG Water Management Policy (DEHP

2012a) and addresses the conditions of the Peat EA (amended as proposed) by:

Decommissioning and remediating four (4) of the five (5) existing CSG water storage ponds;

Prioritising feasible beneficial use in the vicinity of extraction for dust suppression and

construction activities in accordance with the relevant approval;

Utilising natural evaporation to manage produced water volumes that cannot be feasibly

beneficially used; and

In the event that unexpected weather or unforseen CSG water production lead to a

substantial increase in water levels within GPF Pond 2, excess water will be trucked to

another Australia Pacific LNG development area for beneficial use.

Scheme performance will be assessed via monitoring against a set of measurable criteria. If it is found

that a criterion has not been met, causes will be investigated and, where required to protect EVs,

changes to the scheme made. All incidents will be managed in accordance with the LNG Environmental

Incident Procedure (OEUP-Q1000-PRO-ENV-006).

Australia Pacific LNG is committed to regularly reviewing the Peat CWMP in order to establish whether

new or optimised CSG water management options are required and if so, whether or not they are

feasible.





Table of Contents EXECUTIVE SUMMARY ............................................................................................................................................. 3

TERMS, ABBREVIATIONS AND DEFINITIONS ........................................................................................................... 10

ORIGIN ENERGY DOCUMENT REFERENCES ............................................................................................................. 12

1. INTRODUCTION .............................................................................................................................................. 13

1.1. BACKGROUND .................................................................................................................................................... 13 1.2. OBJECTIVES OF THE CWMP .................................................................................................................................. 13

2. RESOURCE PROFILE......................................................................................................................................... 16

2.1. OVERVIEW OF THE PEAT DEVELOPMENT AREA .......................................................................................................... 16 2.2. EXISTING INFRASTRUCTURE ................................................................................................................................... 16

2.2.1. GPF Ponds ............................................................................................................................................... 17 2.2.2. Pond 12 Cell 1 and Cell 2 ........................................................................................................................ 17 2.2.3. Pond 32 .................................................................................................................................................. 17

2.3. CSG WATER QUANTITY ....................................................................................................................................... 20 2.3.1. Observed CSG Water Production Rates .................................................................................................. 20 2.3.2. Predicted Future CSG Water Production ................................................................................................ 20

2.4. CSG WATER QUALITY .......................................................................................................................................... 21

3. EXISTING ENVIRONMENT ............................................................................................................................... 28

3.1. CLIMATE ............................................................................................................................................................ 28 3.2. LAND ................................................................................................................................................................ 28

3.2.1. Topography and Landscape ................................................................................................................... 28 3.2.2. Geology and Soil ..................................................................................................................................... 29 3.2.3. Land Use ................................................................................................................................................. 29

3.3. GROUNDWATER .................................................................................................................................................. 29 3.4. SURFACE WATER ................................................................................................................................................ 30 3.5. ENVIRONMENTALLY SENSITIVE AREAS AND BIODIVERSITY VALUES ................................................................................. 30

4. ENVIRONMENTAL VALUES AND WATER QUALITY OBJECTIVES ....................................................................... 31

4.1. SUMMARY ......................................................................................................................................................... 31 4.2. ENVIRONMENTAL VALUES OF WATER ...................................................................................................................... 31

5. CSG WATER MANAGEMENT STRATEGY .......................................................................................................... 32

5.1. DRIVERS BEHIND THE STRATEGY ............................................................................................................................. 32 5.1.1. Addressing the Conditions of the Peat EA .............................................................................................. 32 5.1.2. Ensuring Alignment to the CSG Water Management Policy .................................................................. 32 5.1.3. Characteristics of the Peat Development Area ....................................................................................... 33

5.2. APPROACH TO DEVELOPING THE STRATEGY .............................................................................................................. 33 5.2.1. Local Needs Analysis and Option Performance Evaluation .................................................................... 34

5.2.1.1. Municipal Water Supply ...................................................................................................................................... 35 5.2.1.2. Agricultural Use ................................................................................................................................................... 36 5.2.1.3. Industrial Use ....................................................................................................................................................... 41 5.2.1.4. Australia Pacific LNG Project Activities ................................................................................................................ 42 5.2.1.5. Injection ............................................................................................................................................................... 42 5.2.1.6. Existing and Planned Beneficial Use Schemes ..................................................................................................... 42 5.2.1.7. Release in a Manner that Improves Local Environmental Values ........................................................................ 43

5.2.2. Summary of Local Needs Analysis and Performance Evaluation ............................................................ 44 5.2.3. Assessment of Priority 2 Options ............................................................................................................ 44

5.2.3.1. Release to Surface Waters ................................................................................................................................... 45 5.2.3.2. Injection ............................................................................................................................................................... 45



Water Solutions, Australia Pacific LNG Upstream Phase 1


5.2.3.3. Evaporation ......................................................................................................................................................... 45 5.2.4. Assessment of Risks to Environmental Values ........................................................................................ 46 5.2.5. Summary of the CSG Water Management Option Assessment ............................................................. 49

5.3. IMPLEMENTING THE REVISED STRATEGY................................................................................................................... 49

6. CSG WATER MANAGEMENT SCHEME ............................................................................................................. 51

6.1. CSG WATER PRODUCTION & GATHERING ............................................................................................................... 51 6.2. CSG WATER STORAGE ......................................................................................................................................... 51 6.3. CSG WATER USE ................................................................................................................................................ 52 6.4. MANAGEMENT OF SALINE WASTE .......................................................................................................................... 52

7. RISKS, POTENTIAL IMPACTS AND MANAGEMENT ........................................................................................... 53

7.1. RISK ASSESSMENT ............................................................................................................................................... 53 7.2. RESIDUAL RISKS AND ADDITIONAL MITIGATION MEASURES ......................................................................................... 53

7.2.1. Existing CSG Water Management Scheme ............................................................................................. 53 7.2.2. Revised CSG Water Management Scheme ............................................................................................. 53

8. MANAGEMENT CRITERIA ................................................................................................................................ 57

9. MONITORING ................................................................................................................................................. 60

9.1. INTEGRITY OF CSG WATER STORAGE PONDS ............................................................................................................ 60 9.2. GROUNDWATER .................................................................................................................................................. 60 9.3. CSG WATER USE ................................................................................................................................................ 61 9.4. DECOMMISSIONING AND REMEDIATION .................................................................................................................. 61

10. MANAGEMENT SYSTEMS AND RECORDS .................................................................................................... 62

10.1. HEALTH, SAFETY AND ENVIRONMENT MANAGEMENT SYSTEM ................................................................................. 62 10.2. PROJECT DELIVERY PROCESS .............................................................................................................................. 62

10.2.1. Environmental Data Management System ............................................................................................ 62 10.2.2. Exploration and Production Operations Management System .............................................................. 62 10.2.3. Enterprise Asset Management System ................................................................................................... 62 10.2.4. Origin Collective Intelligence System ...................................................................................................... 63 10.2.5. ATLAS Compliance Reporting and Recording System ............................................................................. 63

10.3. RISK REGISTERS .............................................................................................................................................. 63 10.4. ROLES AND RESPONSIBILITIES ............................................................................................................................ 63

11. RESPONSE AND REPORTING ....................................................................................................................... 64

11.1. ROUTINE ....................................................................................................................................................... 64 11.2. NON-ROUTINE ................................................................................................................................................ 64

12. REVIEW AND UPDATE OF THE CSG WATER MANAGEMENT STRATEGY ....................................................... 65

13. REFERENCES ................................................................................................................................................ 66

APPENDIX A - ASSESSMENT OF RISKS TO ENVIRONMENTAL VALUES ..................................................................... 68

APPENDIX B - RESPONSIBILITIES FOR CSG WATER MANAGEMENT ......................................................................... 73





List of Tables

Table 1-1: Proposed Amendments to Peat EA ...................................................................... 13

Table 1-2: Summary Requirements of Legislation, Guidelines and Approval Conditions ................... 14

Table 2-1: Existing CSG Water Storage Ponds ...................................................................... 16

Table 2-2: Observed CSG Water Production ........................................................................ 20

Table 2-3: Predicted Future Annual CSG Water Production...................................................... 21

Table 2-4: CSG Water Quality Sampled at CSG Wells ............................................................. 22

Table 2-5: CSG Water Quality Sampled at Ponds .................................................................. 25

Table 3-1: Land Use in the Peat Development Area ............................................................... 29

Table 3-2: Landholder Bore Assessment ............................................................................. 30

Table 4-1: Summary of Environmental Values ...................................................................... 31

Table 4-2: Summary of Environmental Values of Water .......................................................... 31

Table 5-1: Categories of CSG Water Management Option ........................................................ 34

Table 5-2: Option Selection Criteria ................................................................................. 35

Table 5-3: Municipal Water Entitlements ........................................................................... 35

Table 5-4: Land Use in the Peat Development Area ............................................................... 39

Table 5-5: Existing Cattle Feedlots and Piggeries ................................................................. 39

Table 5-6: Water Quality Limit Levels for Irrigation and Stock Watering ..................................... 40

Table 5-7: Landholder Consultation .................................................................................. 40

Table 5-8: Existing and Proposed Coal Mines ....................................................................... 41

Table 5-9: Australia Pacific LNG Water Treatment Facilities and Associated Beneficial Use Schemes .. 42

Table 5-10: CSG Water Quality in Comparison to ANZECC Guideline Values .................................. 44

Table 6-1: Summary Water Balance for Closed Tanks ............................................................. 51

Table 7-1: Risk Assessment for Existing CSG Water Management Scheme .................................... 54

Table 7-2: Risk Assessment for Revised CSG Water Management Scheme ..................................... 55

Table 8-1: Management Criteria for the Peat Development Area ............................................... 58

Table 9-1: CSG Water Storage Pond Monitoring Requirements .................................................. 60

Table 9-2: Peat EA Water Quality Limits for Dust Suppression and Construction Activities ................ 61





List of Figures

Figure 2-1: Location Plan ............................................................................................... 18

Figure 2-2: Existing Infrastructure .................................................................................... 19

Figure 2-3: Predicted Future CSG Water Production .............................................................. 21

Figure 3-1: Regional Climate .......................................................................................... 28

Figure 5-1: DEHP Hierarchy for CSG Water Management ......................................................... 32

Figure 5-2: Waste and Resource Management Hierarchy ......................................................... 33

Figure 5-3: Land Use, Feedlots and Piggeries ...................................................................... 38

Figure 5-4: Predicted Stored CSG Water Volume in GPF Pond 2 ................................................ 46

Figure 5-5: Australia Pacific LNG Risk Matrix ....................................................................... 47





Terms, Abbreviations and Definitions

Term/Abbreviation Definition

AEP Annual exceedance probability

ANZECC Guideline Australian and New Zealand Guidelines for Fresh and Marine Water Quality (ANZECC

and ARMCANZ 2000)

Australia Pacific LNG Australia Pacific LNG Pty Limited

BoM Australian Government Bureau of Meteorology

BUA Beneficial use approval

CSG Coal seam gas

CSG water Water produced from a CSG well to enable gas production

CWMP CSG Water Management Plan (referred to as an AWM Plan in the Peat EA)

DAFF Queensland Government Department of Agriculture, Fisheries and Forestry

DEHP Queensland Government Department of Environment and Heritage Protection

DNRM Queensland Government Department of Natural Resources and Mines

DSA Design storage allowance

EA Environmental authority

EAMS Enterprise Asset Management System

EP Act Environmental Protection Act 1994 (Qld)

EPOMS Exploration and Production Operations Management System

EPP Water Environmental Protection (Water) Policy 2009 (Qld)

ESA Environmentally sensitive area

EV Environmental value

GAB Great Artesian Basin

General BUA General Beneficial Use Approval

GPF Gas Processing Facility

HDPE High density polyethylene

HSE Health, safety and environment

HSEMS Health, Safety and Environment Management System

LNG Liquefied natural gas

OCIS Origin Collective Intelligence System

Origin Energy Origin Energy Resources Limited

PDP Project delivery process

Peat development area Area encompassing petroleum lease PL101

Peat EA Environmental authority EPPG00653413 (26 February 2014)

PL Petroleum lease

QLUMP Queensland Land Use Mapping Program





Term/Abbreviation Definition

SCL Strategic cropping land

TDS Total dissolved solids

TEP Transitional Environmental Program

TOWL Top operating water level

Treated CSG water Water produced from a CSG well which has undergone treatment prior to end use

Untreated CSG water Water produced from a CSG well which has not undergone treatment prior to end use

WQO Water quality objective

WTF Water treatment facility





Origin Energy Document References

Document Reference

Talinga-Condabri Integrated Coal Seam Gas Water Management Plan Q-1000-15-MP-0016

Combabula Coal Seam Gas Water Management Plan Q-4200-15-MP-1077

Spring Gully Coal Seam Gas Water Management Plan Q-8200-15-MP-0001

Constraints Planning and Field Development Protocol Q-LNG-15-MP-0109

Disturbance Procedure OEUP-Q1000-PRO-ENV-001

Risk Policy ORG-RISK-POL-001

Risk Management Directive ORG-RISK-DVE-001

Dam and Pond Inspection Guide OEUP-INT1000-GDL-ENG-021

Peat Rehabilitation Plan Q-8100-15-MP-005

Peat Produced Water Storage Facility Groundwater Monitoring Plan OEUP-Q8100-PLN-ENV-002

Land Transport Directive ORG-HSE-DVE-001

Fatigue Risk Management Directive ORG-HSE-DVE-043

Environmental Management Plan: The Peat Gas Plant OEUP-Q8100-PLN-ENV-001

Environmental Constraints Assessment - Preparation and Issue Q-LNG01-15-AW-0014

Biosecurity Management Specification OEUP-Q1000-SPF-ENV-005

LNG Environmental Incident Procedure OEUP-Q1000-PRO-ENV-006

Dam and Pond Inspection Guide OEUP-INT1000-GDL-ENG-021

Dam Inspection Schedule A-1000-20-PS-001

Asset Integrity Management Plan for Dams Q1000-PLN-ENG-002

Procedure for Conducting Annual and Comprehensive Dam Inspections A-1000-20-AP-001

Crisis and Emergency Management Directive ORG-HSE-DVE-003

Incident Management Directive ORG-HSE-DVE-006

Emergency Response Plan: Peat Gas Plant and Field OEUP-Q8100-PLN-SAF-002





1. Introduction

1.1. Background

The Peat development area is located between the towns of Wandoan, Taroom and Miles in south central

Queensland and extends across petroleum lease (PL) 101, an area of approximately 24,000 ha. Coal seam

gas (CSG) production in the Peat development area commenced in late 2000, with operations undertaken

by Origin Energy Resources Limited (Origin Energy) on behalf of Australia Pacific LNG Pty Limited

(Australia Pacific LNG).

CSG activities are authorised by environmental authority (EA) EPPG00653413 (the Peat EA), issued by the

Queensland Government Department of Environment and Heritage Protection (DEHP) on 10 March 2015.

The process of producing gas from CSG wells produces water (herein termed CSG water) which will be

managed in accordance with this CSG water management plan (CWMP).

1.2. Objectives of the CWMP

This CWMP has the objective of safely and appropriately managing CSG water in order to protect

environmental values (EVs) whilst balancing social and economic considerations. It describes the

approach to CSG water management by considering the specific characteristics of CSG water production

in the Peat development area as well as local demands for this resource from water users. This CWMP

also supports an application to amend Condition (D3) of the Peat EA and to add a new condition as

outlined in Table 1-1.

Table 1-1: Proposed Amendments to Peat EA

Condition Proposed Amendment

D3

Existing Condition (D3):

The holder of this authority must ensure that any ponds used as a primary means of disposal of

associated water are decommissioned, remediated and the area rehabilitated to final land use

standard by 1 November 2011.

Proposed Amended Condition (D3):

Subject to Condition (D16), the holder of this authority must ensure that any ponds used as a

primary means of disposal of associated water are decommissioned by 1 November 2011.

D16 (New)

Proposed New Condition (D16):

Despite Condition (D3) of this environmental authority, Peat GPF Pond 2 may be used as a primary

means of disposal of associated water.

This CWMP has been prepared in accordance with the following documents:

The Peat EA, specifically Condition (D1) to Condition (D9), and the proposed condition

amendments;

The Environmental Protection Act 1994 (Qld) (the EP Act), specifically Section 126; and

The 2012 CSG Water Management Policy, published by DEHP.

Table 1-2 lists relevant requirements from the Peat EA and EP Act and indicates the section of this CWMP

in which each requirement is met.





Table 1-2: Summary Requirements of Legislation, Guidelines and Approval Conditions

Requirement Section Reference

Conditions of the Peat EA

D1 - The holder of this authority must develop and submit, to the administering authority,

an Associated Water Management Plan (AWM Plan)1 for the proposed petroleum activities.

The AWM Plan must adequately identify and quantify all wastes generated and propose

management options for disposing of or beneficially reusing CSG water. The AWM Plan must

address the following matters:

All sections

Identification of environmental issues and potential impacts Section 7

Control measures for routine operations to minimise likelihood of environmental harm Section 7

Contingency plans and emergency procedures for non-routine situations Section 11

Organisational structure and responsibility Section 10.4

Effective communication Section 10.4

Monitoring of contaminant releases Section 9

Conducting environmental impact assessments Section 7

Staff training Section 10.4

Record keeping Section 11

Periodic review of environmental performance and continual improvement Section 11 & 12

D2 - The AWM Plan must set specific performance goals, identify measures to achieve or

maximise the beneficial reuse of CSG water and minimise the generation or emissions of

potential contaminants to the receiving environment. The Plan should:

Section 8

State the objectives to be achieved and maintained under the Plan Section 8

State how the objectives are to be achieved and a timetable to achieve the objectives

taking into account: Section 6

o Best practice environmental management Section 5

o Current technology Section 5

o Risks of environmental harm being caused Section 5

State appropriate performance indicators at time intervals of no more than 12 months Section 8

Make provisions for monitoring and reporting compliance with this Plan Section 9

State how the AWM Plan will comply with the requirements of the 'Queensland Coal

Seam Gas Water Management Policy', released 31 October 2008 [now DEHP 2012a] Section 5

D3 [reflecting proposed amendment] - Subject to Condition (D16), the holder of this

authority must ensure that any ponds used as a primary means of disposal of associated

water are decommissioned by 1 November 2011.

Section 6

D4 – The holder of this authority must submit the AWM Plan for review to the administering

authority within six (6) months after this authority is issued.

Not applicable for

this revision

D5 - The holder of this authority must amend the AWM Plan to reflect any comments

provided by the Administering Authority.

To be completed

following comments

D6 - The holder of this authority must operate all associated water management facilities

in accordance with the AWM Plan.

Demonstrated via

Annual Return

D7 - The AWM Plan must not be implemented or amended in a way that contravenes any

condition of the authority.

Demonstrated via

Annual Return

1 Note that the Peat EA refers to a CWMP as an Associated Water Management Plan (AWM Plan).





Requirement Section Reference

D8 – The holder of this authority must review the AWM Plan every three (3) years. The

review must consider current strategies, best practice alternatives, advances in new

technology, standards and practices in relation to the management of associated water,

new beneficial use proposals and the management of respective waste streams.

Section 5

D9 - Subject to Condition D8 the holder will need to provide justification why existing

management strategies and standards should be continued. Section 5

D16 [Proposed New Condition] - Despite Condition (D3) of this environmental authority,

Peat GPF Pond 2 may be used as a primary means of disposal of associated water Section 5

Section 126 of the EP Act

The quantity of CSG water the applicant reasonably expects will be generated in

connection with carrying out each relevant activity. Section 2.3

The flow rate at which the applicant reasonably expects water will be generated. Section 2.3

The quality of the water, including changes in the water quality that the applicant

reasonably expects will happen while each relevant activity is carried out. Section 2.4

The proposed management of water including use, treatment, storage or disposal. Section 6

The measurable criteria (the management criteria) against which the applicant will

monitor and assess the effectiveness of water management including:

The quantity and quality of the water used, treated, stored or disposed of;

Protection of environmental values affected by each relevant activity; and

The disposal of waste, including, for example, salt.

Section 8

The action proposed to be taken if any of the management criteria are not complied with,

to ensure the criteria will be able to be satisfied in the future. Section 8

Where the proposed management of water provides for using an evaporation dam in

connection with carrying out a relevant activity, include an evaluation of best practice

environmental management that shows there is no feasible alternative.

Section 5





2. Resource Profile

2.1. Overview of the Peat Development Area

The Peat development area is located 14 km east of Wandoan, 62 km southeast of Taroom and 62 km

north of Miles (see Figure 2-1) within the jurisdictional area of the Western Downs Regional Council in

south central Queensland. The development area lies within the Surat Basin and the target formation for

CSG extraction is the Baralaba Formation. The Dawson River sub-catchment of the Fitzroy Basin extends

across the development area and is characterised by a number of ephemeral streams. Existing land use is

dominated by grazing of natural vegetation with some non-irrigated cropping also present.

2.2. Existing Infrastructure

Existing CSG water management infrastructure in the Peat development area is shown in Figure 2-2 and

consists of:

Forty three (43) CSG wells;

A buried high density polyethylene (HDPE) gas and water gathering pipeline network;

The Peat Gas Processing Facility (GPF); and

Five (5) CSG water storage ponds and one (1) interceptor pond (as described in Table 2-1).

Where appropriate, and in accordance with the Peat EA, stored CSG water is currently used for

construction activities and dust suppression within the development area. Any stored water not used for

these activities is evaporated in the CSG water storage ponds.

Table 2-1: Existing CSG Water Storage Ponds

Name Year of

Construction

Northing

Easting

Storage

Volume at

TOWL1 (ML)

Storage

Volume at

Crest (ML)

Liner Hazard

Category2

GPF Pond 1 2000 -26°00.594

150°05.527 0.8 4.19

2mm

HDPE

Significant

GPF Interceptor Pond Unknown -26°00.597

150°05.560 - 0.06

2mm

HDPE

GPF Pond 2 2006 -26°00.430

150°05.517 10.0 21.6

2mm

HDPE Significant

Pond 12 Cell 1 1997 -26°02.650

150°05.414 0.52 1.46 Unlined Significant

Pond 12 Cell 2 1997 -26°02.630

150°05.418 0.73 2.06 Unlined Significant

Pond 32 2003 -26°02.833

150°05.815 15.5 32.12 Bentonite Significant

Table Notes 1 TOWL – Top operating water level 2 Hazard category as assessed in 2013 against the 2012 version of the Manual for Assessing Hazard Categories and Hydraulic

Performance of Dams (DEHP 2012b).





2.2.1. GPF Ponds

The Peat GPF utilises two (2) CSG water storage ponds and a small interceptor pond to manage CSG

water. The interceptor pond is a lined (HDPE) small pit that receives CSG water from CSG wells as well

as receiving process water and rainwater runoff from skids on the site of the GPF. The inlet to the

interceptor pond has a circular baffle which traps oil and other floating contaminants. A single

submerged pipe transfers water from the interceptor pond to GPF Pond 1 by gravity flow. A separate

pipe provides the capability to transfer CSG water between GPF Pond 1 and GPF Pond 2.

Both GPF Pond 1 and GPF Pond 2 receive CSG water direct from CSG wells and are lined with HDPE. The

design and operation of GPF Pond 1 and GPF Pond 2 allows for a 1 in 20 year annual exceedance

probability (AEP) design storage allowance (DSA) above the top operating water level (TOWL) of the

pond. Neither pond has a spillway.

2.2.2. Pond 12 Cell 1 and Cell 2

Pond 12 comprises two (2) unlined cells with earth fill embankments that receive CSG water from CSG

wells. Water can be transferred between the cells by the use of a portable pump and lay flat hose. As

required, water may also be transferred to either of the GPF ponds or Pond 32 by tanker.

The design and operation of Pond 12 Cell 1 and Cell 2 allows for a 1 in 20 year AEP DSA above the TOWL

of the pond. Neither cell has a spillway.

2.2.3. Pond 32

Pond 32 is an earth fill embankment of compacted local material, lined with bentonite. The storage

pond receives CSG water from CSG wells. As required, water may be transferred to the GPF ponds or

Pond 12 Cell 1 or Cell 2 by tanker.

The design and operation of Pond 32 allows for a 1 in 20 year AEP DSA above the TOWL of the pond.

Pond 32 has no spillway.





Figure 2-1: Location Plan





Figure 2-2: Existing Infrastructure





2.3. CSG Water Quantity

2.3.1. Observed CSG Water Production Rates

The Peat development area is a mature asset that has been producing CSG and CSG water since late

2000. As a result, the current rate of CSG water production is low. Table 2-2 shows that over the 12-

month period from June 2013 to May 2014, 9.05 ML of CSG water was produced. In May 2014, the

development area was producing approximately 0.0178 ML of CSG water a day.

Table 2-2: Observed CSG Water Production

CSG Water Storage Pond Number of Wells

Connected to

Pond

Total CSG Water Inflow

to Pond from Jun 2013

to May 2014 (ML)

Rate of CSG Water Inflow

to Pond in May 2014

(ML/d)

GPF Pond 1 13 4.33 0.0099

GPF Pond 2 2 1.92 0.0042

Pond 12 Cell 1 0 - -

Pond 12 Cell 2 1 0.42 0.0008

Peat 32 5 2.38 0.0029

TOTAL 21 9.05 0.0178

2.3.2. Predicted Future CSG Water Production

There are currently no approved plans to expand CSG production in the Peat development area and as a

result, over time, it is expected that the rate of CSG water production will gradually decline. Figure 2-3

presents the future predicted rate of CSG water production from the Peat development area developed

using a numerical reservoir model. This model will be regularly updated as new data allows necessary

model assumptions to be progressively refined. Figure 2-3 shows that:

Between 2015 and 2017, the rate of CSG water production is predicted to fluctuate between

0.019 ML/d and a peak of 0.024 ML/d (predicted to occur in March 2017);

From March 2017 onwards, the rate of CSG water production is predicted to gradually decline

over the remainder of the lifetime of the development area; and

Over the 30 year period from 2014 to 2044, it is predicted that a total of 134 ML of CSG

water will be produced.

Any future proposal to expand CSG production will initiate a review of this CWMP. Table 2-3 presents the

predicted volumes of CSG water production in each year over the next decade.





Figure 2-3: Predicted Future CSG Water Production

Table 2-3: Predicted Future Annual CSG Water Production

Year 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Predicted Volume of CSG

Water Production (ML) 7.1 7.6 8.3 7.4 7.0 6.7 6.4 6.2 6.0 5.7

2.4. CSG Water Quality

The quality of CSG water is primarily dependent on the geology from which the CSG water is produced.

Water quality from a given CSG well is expected to remain relatively consistent over its lifetime however

the quality of CSG water from CSG wells in different parts of a development area may vary.

Table 2-4 and Table 2-5 present the latest CSG water quality data for the Peat development area,

collected from operating CSG wells and ponds in July 2014. DEHP has released general beneficial use

approvals (BUAs) (2014a and 2014b) that identify water quality standards to be met when CSG water is

used for stock watering and irrigation. Based on the median quality of CSG water in the Peat

development area (presented in Table 2-4), CSG water is unsuitable for use for irrigation or stock

watering (see further discussion in Section 5.2.1.2).

Once produced, CSG water is initially gathered to CSG water storage ponds. During the period of storage,

the following natural processes act to alter stored water quality:

Mixing and homogenisation of CSG water from CSG wells from across the development area;

Precipitation of metals caused by contact with atmospheric oxygen;

Settling of fine suspended sediment;

Dissolution of carbon dioxide changing the carbonate-bicarbonate balance and altering pH;

Concentration of constituents such as total dissolved solids (TDS) due to evaporation; and

Change in temperature to approach atmospheric values.





Table 2-4: CSG Water Quality Sampled at CSG Wells

Parameter Unit LOR Samples Detects Min Median Max

Physical / Chemical

pH pH unit 0.01 4 4 8.59 8.62 8.66

Sodium Adsorption Ratio - 0.01 4 4 88.8 114.5 116.0

Electrical Conductivity at 25°C µS/cm 1 4 4 4,920 5,125 5,200

Total Dissolved Solids mg/L 1 4 4 3,200 3,330 3,380

Suspended Solids mg/L 5 4 4 12.0 26.0 74.0

Turbidity NTU 0.1 4 4 3.80 9.45 64.00

Total Hardness as CaCO3 mg/L 1 4 4 21.0 21.5 34.0

Alkalinity

Hydroxide Alkalinity as CaCO3 mg/L 1 4 0 0.5 0.5 0.5

Carbonate Alkalinity as CaCO3 mg/L 1 4 4 109.0 124.5 144.0

Bicarbonate Alkalinity as CaCO3 mg/L 1 4 4 1,080 1,135 1,140

Total Alkalinity as CaCO3 mg/L 1 4 4 1,190 1,265 1,270

Dissolved major anions

Bromide mg/L 0.01 4 4 4.19 4.48 5.27

Iodide mg/L 0.01 4 4 0.86 1.50 1.61

Sulfate as SO4 - Turbidimetric mg/L 1 4 1 0.5 0.5 7

Fluoride mg/L 0.1 4 4 2.0 2.35 2.70

Chloride mg/L 1 4 4 905 1,065 1,170

Dissolved major cations

Calcium mg/L 1 4 4 4 5 7

Magnesium mg/L 1 4 4 2.0 2.5 4.0

Sodium mg/L 1 4 4 1,190 1,200 1,250

Potassium mg/L 1 4 4 9.0 26.5 29.0

Dissolved metals

Aluminium mg/L 0.01 4 1 0.005 0.005 0.02

Arsenic mg/L 0.001 4 0 0.0005 0.0005 0.0005

Boron mg/L 0.05 4 4 2.79 3.72 5.23

Barium mg/L 0.001 4 4 0.342 0.475 0.778

Beryllium mg/L 0.001 4 0 0.0005 0.0005 0.0005

Cadmium mg/L 0.0001 4 0 0.00005 0.00005 0.00005

Cobalt mg/L 0.001 4 0 0.0005 0.0005 0.0005

Chromium mg/L 0.001 4 0 0.0005 0.0005 0.0005

Copper mg/L 0.001 4 1 0.0005 0.0005 0.005

Manganese mg/L 0.001 4 4 0.001 0.008 0.086

Nickel mg/L 0.001 4 1 0.0005 0.0005 0.002

Lead mg/L 0.001 4 1 0.0005 0.0005 0.002

Selenium mg/L 0.01 4 0 0.005 0.005 0.005






Vanadium mg/L 0.01 4 0 0.005 0.005 0.005

Zinc mg/L 0.005 4 0 0.0025 0.0025 0.0025

Lithium mg/L 0.001 4 4 0.066 0.072 0.081

Molybdenum mg/L 0.001 4 1 0.0005 0.0005 0.010

Dissolved Mercury mg/L 0.0001 4 0 0.00005 0.00005 0.00005

Silver mg/L 0.001 4 0 0.0005 0.0005 0.0005

Strontium mg/L 0.001 4 4 0.735 0.817 1.020

Tin mg/L 0.001 4 0 0.0005 0.0005 0.0005

Uranium mg/L 0.001 4 0 0.0005 0.0005 0.0005

Iron mg/L 0.05 4 1 0.025 0.025 1.23

Gold mg/L 0.001 4 0 0.0005 0.0005 0.0005

Total metals

Aluminium mg/L 0.01 4 4 0.020 0.040 3.030

Arsenic mg/L 0.001 4 1 0.0005 0.0005 0.001

Boron mg/L 0.05 4 4 2.84 3.67 5.14

Barium mg/L 0.001 4 4 0.513 0.580 0.963

Beryllium mg/L 0.001 4 0 0.0005 0.0005 0.0005

Cadmium mg/L 0.0001 4 2 0.00005 0.00008 0.0002

Cobalt mg/L 0.001 4 2 0.0005 0.0008 0.003

Chromium mg/L 0.001 4 4 0.001 0.002 0.058

Copper mg/L 0.001 4 4 0.002 0.021 0.066

Manganese mg/L 0.001 4 4 0.021 0.079 0.474

Nickel mg/L 0.001 4 4 0.001 0.003 0.022

Lead mg/L 0.001 4 4 0.002 0.011 0.032

Selenium mg/L 0.01 4 0 0.005 0.005 0.005

Vanadium mg/L 0.01 4 0 0.005 0.005 0.005

Zinc mg/L 0.005 4 4 0.009 0.058 0.354

Lithium mg/L 0.001 4 4 0.070 0.076 0.081

Molybdenum mg/L 0.001 4 1 0.0005 0.0005 0.009

Total Recoverable Mercury mg/L 0.0001 4 1 0.00005 0.00005 0.0003

Silver mg/L 0.001 4 0 0.0005 0.0005 0.0005

Strontium mg/L 0.001 4 4 0.783 0.914 1.110

Tin mg/L 0.001 4 2 0.0005 0.0008 0.003

Uranium mg/L 0.001 4 0 0.0005 0.0005 0.0005

Iron mg/L 0.05 4 4 1.18 3.275 30.8

Gold mg/L 0.001 4 0 0.0005 0.0005 0.0005

Nutrients

Ammonia as N mg/L 0.01 4 4 1.26 1.67 1.88






Nitrite as N mg/L 0.01 4 0 0.005 0.005 0.005

Nitrate as N mg/L 0.01 4 2 0.005 0.0013 0.02

Total Phosphorus as P mg/L 0.01 4 4 0.04 0.06 0.10

Total Organic Carbon mg/L 1 4 4 21.0 26.5 41.0

Phenolic compounds

Phenol µg/L 1 4 0 0.5 0.5 0.5

Polynuclear aromatic hydrocarbons

Naphthalene µg/L 1 4 0 0.5 0.5 0.5

Phenanthrene µg/L 1 4 0 0.5 0.5 0.5

Benzo(a)pyrene µg/L 0.5 4 0 0.25 0.25 0.25

Sum of PAH µg/L 0.5 4 0 0.25 0.25 0.25

Total petroleum hydrocarbons

C6 - C9 Fraction µg/L 20 4 0 10 10 10

C10 - C14 Fraction µg/L 50 4 1 25 25 70

C15 - C28 Fraction µg/L 100 4 3 50 235 500

C29 - C36 Fraction µg/L 50 4 3 25 90 1,180

C10 - C36 Fraction (sum) µg/L 50 4 4 110 305 1,680

BTEX

Benzene µg/L 1 4 0 0.5 0.5 0.5

Toluene µg/L 2 4 0 1 1 1

Ethylbenzene µg/L 2 4 0 1 1 1

meta- & para-Xylene µg/L 2 4 0 1 1 1

ortho-Xylene µg/L 2 4 0 1 1 1

Total Xylenes µg/L 2 4 0 1 1 1

Sum of BTEX µg/L 1 4 0 0.5 0.5 0.5

Radiological

Gross alpha Bq/L 0.08 1 0 0.04 0.04 0.04

Gross beta activity - 40K Bq/L 0.1 1 0 0.05 0.05 0.05

Radium 226 Bq/L 0.05 1 0 0.025 0.025 0.025

Radium 228 Bq/L 0.08 1 0 0.04 0.04 0.04

Lead 210 Bq/L 0.05 1 0 0.025 0.025 0.025

Polonium 210 Bq/L 0.05 1 0 0.025 0.025 0.025

Other

Reactive Silica mg/L 0.05 4 4 20.10 24.45 25.30

Table Notes

When calculating the minimum, median and maximum statistics, half the limit of reporting value is used when a ‘less than limit

of reporting’ value is recorded.





Table 2-5: CSG Water Quality Sampled at Ponds


Physical / Chemical

pH pH unit 0.01 2 2 8.04 8.69 9.34

Sodium Adsorption Ratio - 0.01 2 2 66.9 121.95 177.0

Electrical Conductivity at 25°C µS/cm 1 2 2 4,040 7,170 10,300

Total Dissolved Solids mg/L 1 2 2 2,630 4,665 6,700

Suspended Solids mg/L 5 2 2 77 358.5 640

Turbidity NTU 0.1 2 2 129 381.5 634

Total Hardness as CaCO3 mg/L 1 2 2 36 37 38

Alkalinity

Hydroxide Alkalinity as CaCO3 mg/L 1 2 0 0.5 0.5 0.5

Carbonate Alkalinity as CaCO3 mg/L 1 2 1 0.5 485.25 970.0

Bicarbonate Alkalinity as CaCO3 mg/L 1 2 2 844 1,192 1,540

Total Alkalinity as CaCO3 mg/L 1 2 2 844 1,682 2,520

Dissolved major anions

Bromide mg/L 0.01 2 2 3.23 6.32 9.40

Iodide mg/L 0.01 2 2 1.17 1.71 2.24

Sulfate as SO4 - Turbidimetric mg/L 1 2 2 1 6.5 12

Fluoride mg/L 0.1 2 2 1.1 2.95 4.8

Chloride mg/L 1 2 2 902 1,711 2,520

Dissolved major cations

Calcium mg/L 1 2 2 7 7.5 8

Magnesium mg/L 1 2 2 4 4.5 5

Sodium mg/L 1 2 2 929 1,719.5 2,510

Potassium mg/L 1 2 2 52 58 64

Dissolved metals

Aluminium mg/L 0.01 2 1 0.005 0.0075 0.01

Arsenic mg/L 0.001 2 2 0.001 0.007 0.013

Boron mg/L 0.05 2 2 1.72 5.45 9.24

Barium mg/L 0.001 2 2 0.355 0.671 0.986

Beryllium mg/L 0.001 2 0 0.0005 0.0005 0.0005

Cadmium mg/L 0.0001 2 1 0.00005 0.00008 0.0001

Cobalt mg/L 0.001 2 0 0.0005 0.0005 0.0005

Chromium mg/L 0.001 2 0 0.0005 0.0005 0.0005

Copper mg/L 0.001 2 1 0.0005 0.0053 0.01

Manganese mg/L 0.001 2 2 0.001 0.018 0.035

Nickel mg/L 0.001 2 1 0.0005 0.0008 0.0010

Lead mg/L 0.001 2 0 0.0005 0.0005 0.0005

Selenium mg/L 0.01 2 0 0.005 0.005 0.005






Vanadium mg/L 0.01 2 1 0.005 0.0425 0.080

Zinc mg/L 0.005 2 1 0.0025 0.0098 0.0170

Lithium mg/L 0.001 2 2 0.049 0.069 0.089

Molybdenum mg/L 0.001 2 1 0.0005 0.0028 0.0050

Dissolved Mercury mg/L 0.0001 2 0 0.00005 0.00005 0.00005

Silver mg/L 0.001 2 0 0.0005 0.0005 0.0005

Strontium mg/L 0.001 2 2 0.713 1.152 1.59

Tin mg/L 0.001 2 0 0.0005 0.0005 0.0005

Uranium mg/L 0.001 2 1 0.0005 0.0038 0.0070

Iron mg/L 0.05 2 1 0.025 0.538 1.050

Gold mg/L 0.001 2 0 0.0005 0.0005 0.0005

Total metals

Aluminium mg/L 0.01 2 2 0.02 10.21 20.40

Arsenic mg/L 0.001 2 2 0.001 0.0065 0.012

Boron mg/L 0.05 2 2 1.73 5.39 9.05

Barium mg/L 0.001 2 2 0.496 1.368 2.240

Beryllium mg/L 0.001 2 0 0.0005 0.0005 0.0005

Cadmium mg/L 0.0001 2 1 0.0001 0.0003 0.0005

Cobalt mg/L 0.001 2 1 0.0005 0.0038 0.0070

Chromium mg/L 0.001 2 1 0.0005 0.0058 0.011

Copper mg/L 0.001 2 2 0.002 0.014 0.026

Manganese mg/L 0.001 2 2 0.041 0.1925 0.344

Nickel mg/L 0.001 2 1 0.0005 0.0043 0.008

Lead mg/L 0.001 2 1 0.0005 0.0058 0.011

Selenium mg/L 0.01 2 0 0.005 0.005 0.005

Vanadium mg/L 0.01 2 1 0.005 0.0625 0.120

Zinc mg/L 0.005 2 2 0.043 0.071 0.098

Lithium mg/L 0.001 2 2 0.057 0.092 0.127

Molybdenum mg/L 0.001 2 1 0.0005 0.0018 0.0030

Total Recoverable Mercury mg/L 0.0001 2 0 0.00005 0.00005 0.00005

Silver mg/L 0.001 2 0 0.005 0.005 0.005

Strontium mg/L 0.001 2 2 0.771 1.646 2.52

Tin mg/L 0.001 2 0 0.005 0.005 0.005

Uranium mg/L 0.001 2 1 0.0005 0.0043 0.008

Iron mg/L 0.05 2 1 2.02 9.36 16.7

Gold mg/L 0.001 2 0 0.005 0.005 0.005

Nutrients

Ammonia as N mg/L 0.01 2 2 0.02 0.33 0.64






Nitrite as N mg/L 0.01 2 0 0.005 0.005 0.005

Nitrate as N mg/L 0.01 2 2 0.01 0.02 0.02

Total Phosphorus as P mg/L 0.01 2 2 0.42 1.31 2.20

Total Organic Carbon mg/L 1 2 2 1 85.5 170

Phenolic compounds

Phenol µg/L 1 2 0 0.5 0.5 0.5

Polynuclear aromatic hydrocarbons

Naphthalene µg/L 1 2 0 0.5 0.5 0.5

Phenanthrene µg/L 1 2 0 0.5 0.5 0.5

Benzo(a)pyrene µg/L 0.5 2 0 0.25 0.25 0.25

Sum of PAH µg/L 0.5 2 0 0.25 0.25 0.25

Total petroleum hydrocarbons

C6 - C9 Fraction µg/L 20 2 0 10 10 10

C10 - C14 Fraction µg/L 50 2 1 25 862.5 1,700

C15 – C28 Fraction µg/L 100 2 2 100 2,990 5,880

C29 – C36 Fraction µg/L 50 2 2 60 7,430 14,800

C10 – C36 Fraction (sum) µg/L 50 2 2 160 11,280 22,400

BTEX

Benzene µg/L 1 2 0 0.5 0.5 0.5

Toluene µg/L 2 2 0 1 1 1

Ethylbenzene µg/L 2 2 0 1 1 1

meta- & para-Xylene µg/L 2 2 0 1 1 1

ortho-Xylene µg/L 2 2 0 1 1 1

Total Xylenes µg/L 2 2 0 1 1 1

Sum of BTEX µg/L 1 2 0 0.5 0.5 0.5

Radiological

Gross alpha Bq/L 0.08 2 2 0.07 0.15 0.23

Gross beta activity - 40K Bq/L 0.1 2 0 0.05 0.05 0.05

Radium 226 Bq/L 0.05 2 1 0.025 0.06 0.09

Radium 228 Bq/L 0.08 2 2 0.08 0.11 0.13

Lead 210 Bq/L 0.05 2 0 0.025 0.025 0.025

Polonium 210 Bq/L 0.05 2 1 0.025 0.12 0.21

Other

Reactive Silica mg/L 0.05 2 2 3.56 12.03 20.50

Table Notes

When calculating the minimum, median and maximum statistics, half the limit of reporting value is used when a ‘less than limit

of reporting’ value is recorded.





3. Existing Environment

The following chapter provides an overview of the existing environment of the Peat development area.

3.1. Climate

Regional climate data is recorded by the Australian Government Bureau of Meteorology (BoM) at

Wandoan Post Office, Taroom Post Office and Miles Post Office. Based on data recorded at these sites,

the climate of the Peat development area can be summarised as follows and as shown in Figure 3-1:

Sub-tropical and semi-arid with relatively warm and wetter summers and relatively mild and

drier winters;

Mean daily maximum temperatures ranging between 21°C in winter and 34°C in summer;

Mean daily minimum temperatures ranging between 5°C in winter and 21°C in summer;

Mean monthly rainfall ranging between 28 mm in winter and 98 mm in summer; and

Mean monthly evaporation ranging between 60 mm in winter and 226 mm in summer.

Mean maximum and minimum daily temperature recorded at Taroom Post Office (BoM Site Number 035070), 45 km

northwest of the Peat development area. Mean monthly rainfall recorded at Wandoan Post Office (BoM Site

Number 035014), 9 km west of the Peat development area. Mean monthly evaporation recorded at Miles Post Office

(BoM Site Number 042023) 45 km south of the Peat development area.

Figure 3-1: Regional Climate

3.2. Land

3.2.1. Topography and Landscape

The landscape of the Peat development area is characterised by low hills and undulating plains

supporting Brigalow scrub and open forest. The development area lies within the Taroom Downs province

of the Brigalow Belt bioregion and vegetation is dominated by Acacia harpophylla (Brigalow).





3.2.2. Geology and Soil

The Peat development area lies within the Surat Basin which in turn, overlies the Bowen Basin. The

major geological formations in the region are the Back Creek Group, Blackwater Group, Rewan

Formation and Wandoan Formation. The target formation for CSG extraction is the Baralaba Formation,

located at a depth of between 650 m and 1,300 m.

The soils of the region are mainly brown and black non-cracking clays and gilgaied grey cracking clays

with highly erodible subsoils. These soils are typical of the region and are considered vulnerable to

sheet, rill and gully erosion, particularly where large areas have been cleared and sub-soils exposed.

3.2.3. Land Use

Land use in the Peat development area is dominated by the grazing of native vegetation with some non-

irrigated cropping (see Table 3-1). Potential strategic cropping land (SCL) triggered as the Strategic

Cropping Area under the Regional Planning Interests Act 2014 (Qld) covers the majority of the

development area.

Minor land uses by area include irrigated cropping, intensive animal husbandry, mining and utilities. No

townships lie within the development area however rural homesteads are scattered across its extent.

Table 3-1: Land Use in the Peat Development Area

Land Use Category Land within

Peat Development Area (ha)

Percentage of

Peat Development Area

Grazing of native vegetation 19,829 82.5

Cropping (non-irrigated) 3,988 16.6

Surface waters 67 0.28

Irrigated cropping 15 0.06

Intensive animal husbandry 9 0.04

Mining 3 0.01

Utilities 3 0.01

Other 124 0.52

Table Notes

Source: Queensland Land Use Mapping Program, see http://www.qld.gov.au/environment/land/vegetation/mapping/qlump/

3.3. Groundwater

The hydrogeology of the Peat development area is characterised by alternating sandstone aquifers and

siltstone/mudstone aquitards in both the Surat and Bowen Basins. The Injune Creek Group outcrops in

the northern part of Peat development area.

Although a number of aquifer formations are present beneath the Peat development area, existing

groundwater users tend to target the shallowest available formation that meets their water quality and

quantity requirements. A baseline assessment of landholder bores in the Peat development area

identified 25 operational bores, most of which extract groundwater from the Hutton Sandstone

Formation (see Table 3-2). Water quality in these formations is variable and at 24 of the bores,

groundwater is extracted for stock and domestic use. Groundwater from the other bore is used for stock

and domestic purposes and irrigation.





Table 3-2: Landholder Bore Assessment

Target Formation / Aquifer Number of

Operational Bores

Groundwater Use for

Stock and Domestic

Groundwater Use for Stock,

Domestic and Irrigation

Injune Creek Group 5 5 -

Hutton Sandstone 10 10 -

Precipice Sandstone 8 7 1

Unknown 2 2 -

TOTAL 25 24 1

3.4. Surface Water

The Peat development area lies within the Dawson River catchment, part of the broader Fitzroy Basin,

and is crossed by a number of ephemeral creeks (typically stream order 3 or less) that generally flow in

westerly and northerly directions to the Dawson River. The most significant of these ephemeral creeks

are Juandah Creek (stream order 4), running southeast to northwest across the far southwest corner of

the development area, and Roche Creek (also stream order 4), running east to west across the north of

the development area. There are no Declared Wild River Areas in the development area.

The existing CSG water storage ponds of the Peat development area all lie within the catchment of

Roche Creek. The course of Roche Creek runs west-northwest for approximately 45 km before joining

Juandah Creek. In turn, Juandah Creek flows into Dawson River a further 40 km downstream.

3.5. Environmentally Sensitive Areas and Biodiversity Values

DEHP mapping2 has identified the following environmentally sensitive areas (ESAs) within the Peat

development area:

Category A – None;

Category B – Endangered regional ecosystems (remnant and mature regrowth – biodiversity

status) in two (2) narrow bands in the north of the development area; and

Category C – Of concern regional ecosystem (remnant biodiversity status) in small and

restricted areas of the south and west of the development area.

Australia Pacific LNG has an ongoing program of ground-truthing ESAs in accordance with the Constraints

Planning and Field Development Protocol (Q-LNG01-15-MP-0109) and the Disturbance Procedure (OEUP-

Q1000-PRO-ENV-001). Essential habitat for fauna species and threatened fauna and flora species listed

under the Nature Conservation Act 1992 (Qld) have been identified in the development area and will

also undergo ground-truthing.

2 Available at http://www.ehp.qld.gov.au/licences-permits/maps_of_environmentally_sensitive_areas.php





4. Environmental Values and Water Quality Objectives

4.1. Summary

Table 4-1 summarises the environmental values (EVs) of the existing environment that have the potential

to interact with the proposed CSG water management scheme (described in Section 6).

Table 4-1: Summary of Environmental Values

Environmental Value Description

Surface Water DEHP (2011) has defined a series of EVs for surface water and groundwater in the Upper

Dawson River Basin and these apply to waters of the Peat development area. Groundwater

Terrestrial ecology ESAs are located within the development area as described in Section 3.5.

Land use and soils Potential SCL covers the majority of the development area. Grazing of natural vegetation

is the dominant land use.

4.2. Environmental Values of Water

The EVs of Queensland waters are specified in supporting documents to the Environmental Protection

(Water) Policy 2009 (Qld) (EPP Water), subordinate legislation to the EP Act. Table 4-2 presents the

surface water and groundwater EVs for the Peat development area as defined by DEHP (2011).

Table 4-2: Summary of Environmental Values of Water

Environmental Value

Upper Dawson Southern Tributaries – developed areas

Surface Water Groundwater

Aquatic ecosystems

Irrigation

Farm supply/use

Stock water

Aquaculture

Human Consumer

Primary Recreation

Secondary Recreation

Visual Recreation

Drinking Water

Industrial Use

Cultural and Spiritual Values

To protect each of the EVs listed in Table 4-2, DEHP (2011) has specified water quality objectives

(WQOs) to be met. In the case of the aquatic ecosystem EV, these WQOs vary depending on the condition

(and associated management intent) of the waters in question. Waters in the Peat development area

are defined as ‘moderately disturbed’.





5. CSG Water Management Strategy

This chapter of the CWMP describes and justifies the strategy for managing CSG water produced in the

Peat development area.

5.1. Drivers behind the Strategy

The development of a revised strategy for CSG water management in the Peat development area has

been influenced by three (3) primary drivers, as discussed in the following sub-sections.

5.1.1. Addressing the Conditions of the Peat EA

This CWMP has been prepared to document a review of, and revision to, the current CSG water

management strategy. It aims to ensure that the implemented options continue to reflect the most

appropriate solution for the development area. As such, this CWMP meets Condition (D8) and (D9) of the

Peat EA.

CSG production in the Peat development area commenced in 2000 and the associated CSG water

management infrastructure was constructed in accordance with the industry standards that prevailed at

that time. Notwithstanding this situation, Australia Pacific LNG acknowledges the need to address

Condition (D3) of the Peat EA which requires that:

Existing (D3) The holder of this authority must ensure that any ponds used as a primary means of

disposal of associated water [CSG water], are decommissioned, remediated and the

area rehabilitated to final land use standard by 1 November 2011.

This CWMP supports an application to amend Condition (D3) of the Peat EA and to add a new Condition

(D16) as follows:

Amended (D3): Subject to Condition (D16), the holder of this authority must ensure that any ponds

used as a primary means of disposal of associated water are decommissioned by 1

November 2011.

New (D16): Despite Condition (D3) of this environmental authority, Peat GPF Pond 2 may be used

as a primary means of disposal of associated water

5.1.2. Ensuring Alignment to the CSG Water Management Policy

The proposed strategy for CSG water management has been developed in accordance with the DEHP

prioritisation hierarchy. This hierarchy is published in the CSG Water Management Policy (DEHP 2012a)

and is presented in Figure 5-1. In line with the requirements of the policy, Priority 1 options have been

preferentially investigated with the intention they are implemented wherever they are proven feasible.

1

Prioritisation Hierarchy for Managing and Using CSG Water

2Treating and disposing of CSG water in a way that

firstly avoids, and then minimises and mitigates

impacts on environmental values.

1 Brine or salt residues are treated to create usable

products wherever feasible

2 Disposing of brine or salt residues in accordance

with strict standards that protect the environment

Using CSG water for a purpose that is beneficial to

one or more of the following:

The environment

Existing or new water users

Existing or new water-dependent industries

Prioritisation Hierarchy for Managing Saline Waste

Figure 5-1: DEHP Hierarchy for CSG Water Management





In order to determine the most appropriate beneficial uses of CSG water (Priority 1 options on the DEHP

prioritisation hierarchy), Australia Pacific LNG has conducted a needs analysis of local water users,

considering those options that:

1. Are closest to the region of extraction;

2. Provide water to existing water users in the region of extraction; and

3. Provide water to new water dependent industries or users in the region of extraction.

Any brine or salt residues created as a result of evaporation from ponds in the Peat development area

will be managed in accordance with the DEHP hierarchy for saline waste.

In addition to being developed in accordance with the DEHP prioritisation hierarchies, the strategy for

CSG water management also gives due regard to the waste and resource management hierarchy outlined

in the Waste Reduction and Recycling Act 2011 (Qld) and presented in Figure 5-2.

Figure 5-2: Waste and Resource Management Hierarchy

5.1.3. Characteristics of the Peat Development Area

CSG water production in the Peat development area has several characteristics that influence the

suitability of alternative management options.

1. The rates of CSG water production from the development area are low and are significantly

lower than those observed in other Australia Pacific LNG development areas.;

2. The Peat development area is located a significant distance from other Australia Pacific LNG

development areas (the Combabula development area is the closest, in excess of a 75 km

straight-line distance to the west). It is also located in a region with spatially dispersed water

users (see outcomes of local needs analysis – Section 5.2.1); and

3. The Peat development area is a mature asset with no approved plans for expansion. As such, the

rate of CSG water production is predicted to gradually decline over time. This projected trend

limits the benefit that could otherwise be realised by developing CSG water management

solutions that require large investments in extensive and/or complex infrastructure.

5.2. Approach to Developing the Strategy

Australia Pacific LNG has evaluated the potential performance of more than 70 CSG water management

options for its development areas across south central Queensland. These options are grouped into the

six (6) categories presented in Table 5-1.

• AVOID unnecessary resource consumption 1

• REDUCE waste generation and disposal 2

• RE-USE waste resources without further manufacturing 3

• RECYCLE waste resources to make the same or different products 4

• RECOVER waste resources, including the recovery of energy 5

• TREAT waste before disposal, including reducing the hazardous nature of the waste 6 • DISPOSE of waste only if there is no viable alternative 7





Table 5-1: Categories of CSG Water Management Option

Category Description Position on DEHP

Hierarchy

Municipal use Supply of treated CSG water to townships and into existing municipal

water networks. Priority 1

Agriculture Supply of treated CSG water for agricultural uses including:

a) Existing irrigated cropping or livestock watering operations.

b) To support new irrigation or livestock watering schemes.

c) Agricultural ventures operated by Australia Pacific LNG.

Priority 1

Industrial use Supply of untreated or treated CSG water to industrial users such as

mines (for coal washing for example) and power stations (for cooling). Priority 1

Project

activities

Use of untreated or treated CSG water to support Australia Pacific LNG

Project activities such as dust suppression and construction. Priority 1

Injection Injection of treated CSG water to a depleted aquifer. Priority 1

Beneficial use

schemes

Schemes that combine one or more of the above options in an

integrated beneficial use scheme. Priority 1

Release to

improve EVs

Release to the environment in a manner that improves local

environmental values. Priority 1

Injection Injection of untreated or treated CSG water to a basement formation. Priority 2

Release to

surface water

Release of treated CSG water to surface watercourses in a manner that

ensures the protection of environmental values. Priority 2

In order to determine the most appropriate strategy for managing CSG water in the Peat development

area, each of the option categories in Table 5-1 has undergone a thorough and robust evaluation process

comprising the following two (2) stages:

A water needs analysis and option performance evaluation specific to the Peat development

area, and

A detailed environmental value risk assessment.

Based on the outcomes of these two processes, options were either incorporated into the CSG water

management strategy for the development area or else discounted as currently infeasible. Infeasible

options will still be reconsidered during updates to the CWMP (as described in Section 12).

5.2.1. Local Needs Analysis and Option Performance Evaluation

The following sub-sections identify the local needs for water in the Peat development area and analyse

options for supplying CSG water to meet these demands. For each option, consideration has also been

given to likely performance against the selection criteria outlined in Table 5-2.





Table 5-2: Option Selection Criteria

Category Criteria

Regulatory Compliance Position of option on DEHP hierarchy

Compliance with waste and resource management hierarchy

Cost Net present cost of option over lifetime and over first five (5) years of life

Level of uncertainty associated with net present cost estimate

Health and Safety Ability of the option to be constructed and operated in a manner that ensures the

health and safety of Australia Pacific LNG employees and the community

Environmental Impact The impact of the option on EVs

Water Demand Rate, volume and timing of water demanded by the option

Quality of the water demanded by the option

Social Acceptance Impact of the option on the community and community perception of the option

Impact on Australia Pacific LNG reputation as a result of implementing the option

Execution Complexity Resources required to implement the option

Technical and commercial complexity of implementing the option

Operability Resources required to operate the option over its lifetime, including technical and

commercial complexity

Ability of the option to adapt to changes in CSG water quantity and quality

5.2.1.1. Municipal Water Supply

The three (3) closest townships to the Peat development area (Wandoan, Taroom and Miles) all source

their municipal water supplies from underground aquifers of the Great Artesian Basin (GAB). The Great

Artesian Basin Resource Operations Plan published by the Queensland Government Department of

Natural Resources and Mines (DNRM) in 2012 identifies the annual groundwater entitlements of these

townships as 400 ML, 500 ML and 400 ML respectively (see Table 5-3).

The annual rate of CSG water production from the Peat development area is predicted to peak in 2017 at

8.3 ML (see Table 2-3), equivalent to around 2% of the annual water entitlement of Wandoan. Supplying

CSG water to local townships would therefore only be capable of meeting a very small proportion of

their respective total municipal demands. Furthermore, rates of CSG water production from the Peat

development area are predicted to gradually decline over time, with 6.7 ML predicted to be produced in

2020 and 5.5 ML predicted to be produced in 2025.

Table 5-3: Municipal Water Entitlements

Town Distance from Peat

GPF (km)

Municipal Water

Source

Annual Water

Entitlement

(ML)

Max. Annual Volume of CSG

Water Production as

Percentage of Entitlement

Wandoan 18

Groundwater of

the GAB

400 2.1%

Taroom 50 500 1.7%

Miles 73 400 2.1%

An additional constraint on this option is the need for CSG water to be treated before it can be supplied

for municipal use. The concentration of fluoride in CSG water (Table 2-4) exceeds the health guideline

specified in the Australian Drinking Water Guidelines (NHMRC and NRMMC 2011) (ADWG) whilst other

parameters exist in concentrations that exceed the ADWG aesthetic guideline values. The required

infrastructure would be likely to include:

A water treatment facility, likely to consist of filtration units, a reverse osmosis desalination

unit and chemical dosing facilities;





Treated water and brine storage facilities (to separately manage the treated CSG water and

waste brine products generated as a result of desalination);

Investment in a long-term brine and salt management solution/s;

Power supplies for treatment equipment and pumping facilities;

Chemical storage facilities; and

Ancillary pipeline infrastructure (refer Table 5-3 for distance) to town location or

implementation of water transport via trucking.

Australia Pacific LNG has undertaken an estimation of the capital and operating costs of the above

infrastructure. Given the small volumes of CSG water expected to be produced (an annual maximum of

8.3 ML in 2017, see Table 2-3), for each megalitre of CSG water that could be treated, the cost of the

required infrastructure is far higher than is the case for other development areas of the Australia Pacific

LNG Project (where CSG water production rates are higher). The cost assessment identified that the per

megalitre operating costs of a WTF in the Peat development area would be more than 50 times that of

other Australia Pacific LNG water management schemes. Furthermore, committing to this infrastructure

in order to meet such a small proportion of a township’s municipal water demand, and only for a limited

period of time, is not considered to represent a socially, environmentally or economically beneficial

solution.

5.2.1.2. Agricultural Use

Existing Agricultural Schemes - Irrigation and Stock Watering

Agricultural uses of water include irrigation and stock watering. Maps from the Queensland Land Use

Mapping Program (QLUMP)3 were evaluated to determine the likely water demands from existing

agricultural users in the Peat development area. Figure 5-3 identifies a single small (15 ha) land parcel

supporting irrigated cropping (see Table 5-4) approximately 23 km south of the Peat GPF.

The QLUMP mapping also identifies a small area of ‘intensive animal husbandry’ on the western

boundary of the development area, approximately 12 km southwest of the Peat GPF. Data from the

Queensland Government Department of Agriculture Fisheries and Forestry (DAFF) suggests that this land

corresponds to a feedlot supporting a maximum 999 head of cattle (see Table 5-5). Two (2) other

feedlots within the development area support a combined maximum of 800 head of cattle and are

located 13 km south and 14 km southwest of the Peat GPF respectively. A feedlot 10 km to the

northwest of the Peat GPF but outside the Peat development area supports a maximum of 499 cattle.

Table 9.3.1 of the Australian and New Zealand Guidelines for Fresh and Marine Water Quality (ANZECC

and ARMCANZ 2000) (ANZECC Guideline) indicates that on average, daily water consumption by beef

cattle is in the order of 45 L/head. Using this estimate, the four (4) feedlots within 15 km of the Peat

GPF could require around 0.103 ML of stock water a day at maximum stocking capacity. It is therefore

possible that the predicted peak rate of CSG water production from the Peat development area (0.024

ML/d) could meet the stock watering demand of one (1) of these feedlots for a limited period of time.

However, as CSG water production is predicted to gradually decline over time, an additional water

supply (and the associated duplication of water supply infrastructure) would also be required by the

feedlot owner. Investment in multiple water supply schemes is unlikely to be cost effective and would

also create complex operational constraints. For reference, Table 5-5 also identifies other feedlots and

piggeries within the region immediately beyond the Peat development area boundary.

General BUAs (DEHP 2014a and 2014b) specify water quality guidelines for stock watering and irrigation

respectively and also impart obligations on the producers and users of the CSG water resource. Table 5-6

presents the water quality criteria from the respective General BUAs against CSG water quality data

reproduced from Table 2-4. This comparison shows that CSG water from the Peat development area is

likely to require treatment prior to use for either irrigation or stock watering. The maximum electrical

conductivity, sodium adsorption ratio, pH, iron concentration and fluoride concentration of CSG water

exceed the General BUA requirements for irrigation whilst the maximum concentration of fluoride and

3 See http://www.qld.gov.au/environment/land/vegetation/mapping/qlump/





boron in CSG water exceeds the General BUA requirement for stock watering. The water treatment

infrastructure constraints outlined in Section 3.2.1.1 are therefore also relevant to the option of

supplying CSG water to agricultural users.

In order to understand the demand for CSG water from landholders in the vicinity of the Peat GPF,

Australia Pacific LNG completed a consultation process in December 2014. Table 5-7 lists the

landholders that were consulted and their locations relative to CSG water management infrastructure.

All of the landholders consulted confirmed that they would not be willing to accept CSG water at the

qualities and in the volumes expected for the Peat development area.

The option of providing CSG water to supplement larger regional agricultural supply schemes is

considered in Section 5.2.1.6.

New Agricultural Schemes – Irrigation and Stock Watering

An alternative to supplying existing agricultural schemes is for Australia Pacific LNG to either establish

its own agricultural venture, or to supply local landholders with CSG water for this purpose. Australia

Pacific LNG has successfully implemented this approach in both the Spring Gully development area

(around 100 km west of the Peat development area) and in the Talinga/Condabri region (around 100 km

to the south). However, in these cases, the success of the schemes has been reliant on sustained rates of

CSG water production over many years. In the Peat development area, the predicted gradual decline in

CSG water production prevents the establishment of a long-term sustainable agricultural venture that

would otherwise provide social benefit. Any agricultural scheme in the Peat development area would

require an alternative water supply on which it would become increasingly reliant. The necessary

duplication of infrastructure therefore makes the development of, or support for, a new agricultural

venture by Australia Pacific LNG environmentally and economically infeasible. Furthermore, as for

existing agricultural schemes, CSG water would require treatment (and the development of necessary

infrastructure) prior to use at new agricultural ventures.





Figure 5-3: Land Use, Feedlots and Piggeries





Table 5-4: Land Use in the Peat Development Area

Land Use Category Land within Peat Development Area (ha)

Percentage of Peat Development Area

Grazing of native vegetation 19,829 82.5 %

Cropping (non-irrigated) 3,988 16.6 %

Surface waters 67 0.28 %

Irrigated cropping 15 0.06 %

Intensive animal husbandry 9 0.04 %

Mining 3 0.01 %

Utilities 3 0.01 %

Other 124 0.52 %

Table Notes

Data source: http://www.qld.gov.au/environment/land/vegetation/mapping/qlump/

Table 5-5: Existing Cattle Feedlots and Piggeries

Ref. Distance A from Peat GPF (km) Registered Maximum Operating

Capacity (head of cattle)

Water Demand for Stock

Watering (ML/d) B

Cattle Feedlot

1 13 500 0.023

2 14 300 0.014

3 11.5 999 0.045

4 26.5 985 0.044

5 28.5 499 0.022

6 27.5 499 0.022

7 31 499 0.022

8 10 499 0.022

9 33.5 5,000 0.225

10 22 150 0.007

11 23 150 0.007

Piggery

A 26 60 0.001

Table Notes

A – Direct distance. If water supply were to be via tanker, travelled distance would be greater.

B - Stock water requirements for both cattle and pigs as stated in Table 9.3.1 of the Australian and New Zealand Guidelines for

Fresh and Marine Water Quality (ANZECC and ARMCANZ 2000)





Table 5-6: Water Quality Limit Levels for Irrigation and Stock Watering

Parameter Unit Water Quality Limit for

Irrigation A

Water Quality Limit for

Stock Watering B

CSG Water

Quality C

Electrical conductivity µS/cm 950 D No limit 5,200

Sodium adsorption ratio - 6 E No limit 116

pH - 6.0 – 8.5 F No limit 8.66

Total dissolved solids mg/L No limit 4,000 G 3,380

Aluminium mg/L 20 5 3.03

Arsenic mg/L 2 0.5 0.001

Boron mg/L Crop dependent H 5 5.14

Cadmium mg/L 0.05 0.01 0.0002

Chromium mg/L 1 1 0.058

Cobalt mg/L 0.1 1 0.003

Copper mg/L 5 1 I 0.066

Fluoride mg/L 2 2 2.7

Iron mg/L 10 No limit 30.8

Lithium mg/L 2.5 No limit 0.081

Lead mg/L 5 0.1 0.032

Manganese mg/L 10 No limit 0.474

Mercury mg/L 0.002 0.002 0.0003

Molybdenum mg/L 0.05 0.15 0.009

Nickel mg/L 2 1 0.022

Selenium mg/L No limit 0.02 <0.01

Uranium mg/L No limit 0.2 <0.001

Zinc mg/L 5 20 0.354

Gross alpha Bq/L No limit 0.5 <0.08

Gross beta (excl. K-40) Bq/L No limit 0.5 <0.1

Radium 226 Bq/L No limit 5 <0.05

Radium 228 Bq/L No limit 2 <0.08

Table Notes A As in the General Beneficial Use Approval: Irrigation of Associated water (including coal seam gas water) (DEHP 2014b). B As in the General Beneficial Use Approval: Associated water (including coal seam gas water) (DEHP 2014a). Water quality limit

levels for stock watering assume that stock feed contains no heavy metals. C Maximum value for the Peat development area

based on data from operating CSG wells in 2014. See Table 2-4 for full suite. D As a 95th percentile over one-year period. E For heavy soils (clay content > 35%) as a 95th percentile over a one-year period. For light soils (clay content < 35%) limit is 12. F Accounting for atmospheric equilibrium as a 95th percentile over one-year period. G For beef cattle. Other limits apply for dairy

cattle and other livestock. H Refer to Table 9.2.18 of the Australian and New Zealand Guidelines for Fresh and Marine Water

Quality (ANZECC and ARMCANZ 2000). I For cattle. Other limits apply to other livestock.

Table 5-7: Landholder Consultation

Location of Landholder Landholder / Feedlot Owner Date of Consultation

Land surrounding Pond 12 and Pond 32 Landholder 11 Dec 2014

13 km south of Peat GPF (Ref. 1 in Figure 5-3) Feedlot Owner 1 Dec 2014

Land surrounding Peat GPF Landholder 8 Dec 2014





5.2.1.3. Industrial Use

In support of the Australia Pacific LNG Project Environmental Impact Statement (2010), an industrial

water demand assessment identified existing and planned coal mines in the region. The study concluded

that whilst future mining developments could represent a relatively large and reliable demand of water,

demands from operating mines are likely to be satisfied by existing arrangements.

The Queensland Government’s Interactive Resource and Tenure Map4 was used to identify coal mining

leases within and in the vicinity of the Peat development area. Table 5-8 shows that the closest

operating coal mine to the Peat development area is Cameby Downs. No water use data for this mine is

available however it is understood that demands are already met by an industrial water treatment plant.

Of those mines currently proposed within the region, demands for water far exceed those which could be

met by CSG water produced in the Peat development area. The maximum predicted rate of CSG water

production is less than 1% of the daily demand from any of the proposed mines listed in Table 5-8.

Furthermore, none of these mines have been approved and committed for implementation.

The proposed Wandoan Coal Project includes the development of combined cycle gas-fired generators

(Xstrata Coal 2009). Such a facility, if built, may have a requirement for water for cooling however the

required volume, and a decision on whether to proceed with construction of the plant, has yet to be

made. No other power plants or proposed power plants lie within 50 km of the Peat development area.

Given that no existing unmet demands of water from industrial sources exist in the region of the Peat

development area, the option of supplying CSG water to industrial water users is considered infeasible.

Supplying CSG water to Australia Pacific LNG project activities is considered in Section 5.2.1.4.

Table 5-8: Existing and Proposed Coal Mines

Coal Mine Status Estimated

Mining Start

Date A

Distance from Centre

of Development Area

(km)

Water

Demand A B

(ML/d)

Max Rate of CSG

Water Production as

Percentage of Demand

Cameby Downs Existing - 85 Unknown -

Collingwood Proposed Q2 2015 12 8.6 0.28 %

The Range Proposed 2015 18 4.1 0.59 %

Wandoan Proposed Unknown 13 24.9 0.10 %

Taroom Proposed Q2 2015 46 11.5 0.21 %

Elimatta Proposed Q2 2017 44 9.8 0.24 %

Table Notes A Mining start date and water demand estimates sourced from respective Environmental Impact Statements, see

Section 13 for references. B Assumed constant based on total demand, start date and production lifetime.

Australia Pacific LNG has also discussed the possibility of supplying CSG water from the Peat

development area for treatment by another CSG operator in the region. A meeting with a regional CSG

operator was held in 2014 however Australia Pacific LNG was not satisfied that beneficial use of any

supplied CSG water could be assured. Further discussions were therefore not progressed. Even if

concerns over beneficial use could be addressed, Australia Pacific LNG notes that the delay to the

execution of the project associated with negotiating appropriate commercial arrangements with the

other CSG operator would defer implementation by a considerable period of time.

4 See http://mines.industry.qld.gov.au/geoscience/interactive-resource-tenure-maps.htm





5.2.1.4. Australia Pacific LNG Project Activities

Several activities associated with the development of CSG (and its supporting infrastructure) require

water. The suppression of dust on roads and the construction of facilities are common examples and

water demands from these activities are likely to exist in close proximity to the Peat GPF. The Peat EA

specifies water quality limits for water to be used for dust suppression and civil construction works and

is possible that untreated CSG water may comply with these requirements. Where this is the case, use of

CSG water to support short-term project activities conducted by Australia Pacific LNG would represent a

feasible beneficial use option in the Peat development area.

5.2.1.5. Injection

This option involves the injection of CSG water to a depleted aquifer to promote recharge for the

benefit of groundwater users (including the environment). To ensure that the water quality of the

receiving aquifer is not altered, prior treatment of the CSG water is likely to be required. Given the

predicted volumes of CSG water expected to be produced in the Peat development area, the

construction of the necessary gathering, treatment and injection infrastructure is considered an

uneconomic management option.

5.2.1.6. Existing and Planned Beneficial Use Schemes

Beneficial Use Schemes operated by Australia Pacific LNG

Australia Pacific LNG currently operates several schemes for the beneficial use of CSG water in south

central Queensland (see Table 5-9). Each of these schemes consists of a water treatment facility (WTF)

and a portfolio of beneficial uses aligned to the DEHP prioritisation hierarchy. Using CSG water from the

Peat development area to supplement these schemes is currently considered infeasible as a long-term

strategy on the basis that:

The predicted maximum rate of CSG water production in the Peat development area equates

to less than 0.3% of the maximum capacity of any one of the existing or planned Australia

Pacific LNG beneficial use schemes; and

All beneficial use schemes are located in excess of a 75 km straight-line distance from the

Peat development area. The financial cost and social and environmental impact of

constructing a pipeline over this distance, or those associated with establishing regular, long-

distance truck movements are considered prohibitive.

Notwithstanding this conclusion, should rates of CSG water accumulation in water storages in the Peat

development area significantly exceed those predicted, stored CSG water could be trucked to one of the

Australia Pacific LNG beneficial use schemes in Table 5-9 as a short-term management measure.

Table 5-9: Australia Pacific LNG Water Treatment Facilities and Associated Beneficial Use Schemes

WTF Distance from Peat GPF (km)

Capacity (ML/d)

Beneficial Use Portfolio Document Reference

Talinga

WTF

105 20 Supply to landholders for agricultural

use;

Use for project activities;

Supply to industrial activities; and

As a contingency to the above beneficial

uses, release to surface water.

Talinga-Condabri

Integrated Coal Seam

Gas Water

Management Plan

(Q-1000-15-MP-0016) Condabri

WTF

95 40

Reedy

Creek WTF

80 40 Use for project activities; and

Supply to aquifer injection.

Combabula Coal

Seam Gas Water

Management Plan

(Q-4200-15-MP-1077)





WTF Distance from Peat GPF (km)

Capacity (ML/d)

Beneficial Use Portfolio Document Reference

Spring

Gully WTF

110 12 Use for project activities;

Supply to aquifer injection;

Supply to irrigation and livestock

watering; and

As a contingency to the above beneficial

uses, release to surface water.

Spring Gully Coal

Seam Gas Water

Management Plan

(Q-8200-15-MP-0001)

Beneficial Use Schemes operated by Third-Parties

The Woleebee Creek to Glebe Weir Pipeline is a 120 km pipeline from QGC’s Woleebee Creek Water

Treatment Plant to Glebe Weir on the Dawson River. The pipeline is operated by SunWater and its

alignment runs southwest to northwest approximately 10 km northwest of the Peat GPF. The pipeline is

capable of supplying a maximum of 36,500 ML/yr of treated CSG water to agricultural and industrial

customers along its alignment as well as to customers within the Dawson Valley Water Supply Scheme.

The pipeline commenced operation in February 2015 (SunWater 2015).

The option to supply CSG water from the Peat development area to the Woleebee Creek to Glebe Weir

pipeline would require treatment of the CSG water. Alternatively, untreated CSG water could be

delivered to the QGC water treatment plant located approximately 35 km southwest of the Peat GPF. A

commercial agreement would have to be reached between the relevant parties in either case.

Any supply of CSG water would require a water treatment plant and a connecting pipeline or regular

truck movements from the Peat GPF over a distance of at least 10 km. Given that the forecast maximum

rate of CSG water production in the Peat development area represents just 0.02% of the maximum rate

of supply along the Woleebee to Glebe Weir Pipeline, it is considered that the cost and social and

environmental constraints associated with pipeline construction or trucking, and potential water

treatment, render the option infeasible at this time.

5.2.1.7. Release in a Manner that Improves Local Environmental Values

The course of Roche Creek (the closest watercourse to the CSG water management infrastructure of the

Peat development area) runs from east to west, approximately 0.5 km north of Pond 12 and Pond 32 and

approximately 3.5 km south of the Peat GPF. Roche Creek is an ephemeral watercourse and as such, the

flora and fauna species it supports will be adapted to an intermittent flow regime. The watercourse

forms part of the Upper Dawson sub-catchment for which EVs include aquatic ecosystems (moderately

disturbed) and agricultural uses (see Table 4-2).

The quality of CSG water produced in the Peat development area (see Table 5-10) does not meet the

ANZECC Guideline values for the protection of freshwater aquatic ecosystems for several parameters

which include pH, electrical conductivity, aluminium, boron and zinc. As such, any release scheme

would require that CSG water undergoes prior treatment. As described in Section 5.2.1.1, the costs of

treatment are considered prohibitive given the low volumes of CSG water expected to be produced.

Therefore, release to the environment in a manner that improves local environmental values is

considered infeasible as a management option for the Peat development area at this time.





Table 5-10: CSG Water Quality in Comparison to ANZECC Guideline Values

Parameter Unit

Median Value for CSG Water Quality

Sampled at CSG Wells A

Median Value for CSG Water Quality Sampled at Ponds B

ANZECC Guideline values for the protection of

freshwater aquatic ecosystems

Physical / Chemical

pH pH unit 8.62 8.69 6.5 – 8.0

Electrical Conductivity at 25°C µS/cm 5,125 7,170 370 C

Dissolved metals

Aluminium mg/L 0.005 0.0075 0.0055

Boron mg/L 3.72 5.45 0.370 D

Zinc mg/L 0.0025 0.0098 0.008

Table Notes A – See Table 2-4 for full dataset. B - See Table 2-5 for full dataset. C - Based on sub-regional low flow water quality guidelines derived by the department as part of the process to establish EVs and

WQOs in the Fitzroy Basin (DEHP 2011). D – Results of Direct Toxicity Assessments completed for the Dawson (Halcrow 2012) and Condamine-Balonne (Aqua Della Vita

2014) catchments, support a freshwater aquatic ecosystem trigger value of 1 mg/L, however the concentration of boron within

Peat CSG water is in excess of this value also.

5.2.2. Summary of Local Needs Analysis and Performance Evaluation

The local needs analysis for the Peat development area has highlighted that:

CSG water has the potential to be beneficially used locally by project activities undertaken

by Australia Pacific LNG. These uses will be dependent on the specific quality of the CSG

water available at the time of the demand and is unlikely to utilise the total volume of CSG

water produced within the Peat development area;

There is no demand for CSG water from consulted landholders in the vicinity of key CSG

water management infrastructure;

Third-party local water users typically require a high quality of water that cannot be met by

CSG water without its prior treatment;

The capital and operating costs of treating CSG water are prohibitive considering the small

volumes of CSG water forecast to be produced;

The predicated gradual decline in CSG water production over time prevents the

establishment of long-term sustainable beneficial use schemes reliant on CSG water.

Development of the necessary infrastructure to supply water is therefore not economically

sustainable; and

Outside the Peat development area, CSG water could be delivered to existing and planned

beneficial schemes in other Australia Pacific LNG development areas however because of the

distances involved, this is does not represent a suitable primary management option. It could

however be used effectively as a short-term measure to manage unexpected volumes of

water (such as those associated with wet weather for example).

5.2.3. Assessment of Priority 2 Options

In light of the conclusions of the local needs analysis, Priority 2 CSG water management options on the

DEHP prioritisation hierarchy were also evaluated against the option selection criteria presented in Table

5-2.





5.2.3.1. Release to Surface Waters

Surface watercourses in the Peat development area are ephemeral and characterised by extended dry

periods with short-lived flow events in response to rainfall. Any release of CSG water to surface

watercourses would require its prior treatment in order to protect EVs. Given the small volumes of CSG

water requiring management, development of the necessary infrastructure to allow for surface water

release is considered uneconomic (see Section 5.2.1.1) and the option therefore considered infeasible at

this time.

5.2.3.2. Injection

This option involves the injection of CSG water to suitable underground formations where it provides no

benefit to groundwater users or the environment. Depending on the groundwater quality of the receiving

formation, it may be possible to use untreated CSG water for this purpose. However, given the

predicted small volumes of CSG water expected to be produced within the Peat development area, the

construction of the necessary injection infrastructure is considered to represent an uneconomic

management option. Injection is therefore considered infeasible as a CSG water management option for

the Peat development area at this time.

5.2.3.3. Evaporation

The climate of the Peat development area is characterised by net evaporation in all months (Figure 3-1).

Given the aforementioned limitations regarding beneficial use options commensurate with water

production rates and quality characteristics and the prevailing natural climatic conditions, evaporation

represents a viable and safe water management option for CSG water. Evaporation can be managed in a

way which poses no significant risk to EVs (see further discussion in Section 5.2.4). Additionally, for the

Peat development area, it does not require significant disturbance to be undertaken for new

infrastructure.

Australia Pacific LNG has completed modelling which shows that the low predicted volumes of future

CSG water production in the Peat development area can be safely stored within the existing GPF Pond 2

(see Figure 5-4). Furthermore, as a HDPE-lined pond, evaporation of CSG water from GPF Pond 2 also

poses no significant risk to EVs (see Section 5.2.4 and Section 7).

Figure 5-4 presents the mean and 95th percentile (P95) predicted trend in the future volume of stored

water in GPF Pond 2. The predictions are based on the forecast rate of CSG water production for the

entire Peat development area in addition to Monte Carlo simulations of historic rainfall and evaporation

data. Figure 5-4 shows that even when all the CSG water produced in the Peat development area is

aggregated to a single pond, natural climate means that net water stored is gradually reduced via

evaporation.

Figure 5-4 confirms that GPF Pond 2 has a current maximum operating capacity that significantly

exceeds the mean predicted trend in stored water volume. The P95 scenario shows that there is a 5%

chance that stored volume will approach (but not exceed) current maximum operating capacity in late

2017. If required to maintain pond levels below the maximum operating level of GPF Pond 2 (as

specified in its operational plan), stored CSG water can be trucked for beneficial use in another Australia

Pacific LNG development area.





Figure 5-4: Predicted Stored CSG Water Volume in GPF Pond 2

5.2.4. Assessment of Risks to Environmental Values

Australia Pacific LNG is committed to the continual and effective management of risk and implements a

Risk Policy (ORG-RISK-POL-001) and Risk Management Directive (ORG-RISK-DVE-001) to ensure that:

Systems are in place to identify risks to the extent that is reasonably practicable;

The potential impacts of identified risks are understood and limits are set to ensure their

appropriate management;

Responsibilities for risk management are delegated to appropriate persons;

Assurance is provided as to the effectiveness of the risk management system and its

associated risk controls; and

Any material changes to risk levels are monitored and acted upon accordingly.

To evaluate the risks that each potential CSG water management option of the Peat development area

poses to EVs, the options presented in the local needs analysis were assessed considering all

infrastructure and associated management procedures required for their operation.

Risks to the EVs of air, noise, land and biodiversity, surface water, groundwater, waste and

social/community were then assigned a consequence and likelihood rating assuming existing controls are

in place in accordance with the Australia Pacific LNG risk matrix (Figure 5-5). The ratings were then

combined to derive a risk level on a five-point scale from ‘Low’ to ‘Extreme’. ‘Low’ level risks and some

‘Medium’ level risks of acceptably low severity are considered appropriately mitigated by existing

controls.

For all other risks, additional mitigation measures would be required if the option were to be

implemented, and treatment plans prepared and approved. For ‘Extreme risks’, a treatment plan would

need to be prepared and implemented immediately. The Australia Pacific LNG risk assessment process

complies with International Standard ISO 31000 – Risk Management.





Figure 5-5: Australia Pacific LNG Risk Matrix





Appendix A presents the EV risk assessment of potential CSG water management options in the Peat

Development area. It includes a detailed description of all risks, quantification of risk consequences

(wherever possible), and the identification of applicable existing controls. The outcomes of the risk

assessment show that:

For all CSG water management options:

- All options incur impacts (considered to have a Minor consequence) to the EVs of air, noise, land and biodiversity, waste and social/community. These impacts are associated with transitioning to compliance with the proposed conditions of the Peat EA and specifically reflect the need to truck CSG water between storage infrastructure in the development area or to Australia Pacific LNG Project activities and to implement recommendations from the 2014 Annual Dam Inspection of GPF Pond 2 (SMEC 2014).

For untreated CSG water use options:

- The option of retaining GPF Pond 2 as an evaporation dam is the only option to have a ‘Low’ aggregate risk score. It incurs no additional risks to the EVs of air, noise, waste or social/community. Low risks to the EVs of land and biodiversity, surface water and groundwater are associated with the risk of seepage and overtopping of GPF Pond 2 and can be managed to acceptable levels via the continued implementation of standard control measures (outlined in Appendix A and Section 7);

- The option of converting GPF Pond 2 to an aggregation dam and using untreated CSG water to support Australia Pacific LNG Project activities is considered to have a Medium risk, reflective of the need for additional truck movements. The required transport distances (and therefore the associated emissions, risk of accidents and social disturbances) are however considered manageable using existing controls (outlined in Appendix A and Section 7);

- The option of converting GPF Pond 2 to an aggregation dam and of then using untreated CSG water for industrial supply incurs a High and unacceptable risk score associated with the requirement to truck water over long distances;

- The option of converting GPF Pond 2 to an aggregation dam and of then using untreated CSG water for basement injection incurs a High and unacceptable risk score associated with the disturbances necessary for the construction of injection infrastructure; and

- The options of converting GPF Pond 2 to an aggregation dam and of then using untreated CSG water for aquifer injection, agricultural activities, municipal supply and release to surface waters incur Severe and unacceptable risks to EVs that reflect the unsuitable nature of CSG water quality as compared to relevant guideline criteria.

For treated CSG water use options:

- All treated CSG water options result in the generation of wastes that require subsequent management;

- The option of converting GPF Pond 2 to an aggregation dam and transferring CSG water for treatment at a WTF operated by another CSG company is considered to incur a Medium risk level on the basis of the requirement for regular truck movements. Depending on the distance to the WTF, the risk may be High;

- Options involving the conversion of GPF Pond 2 to an aggregation dam and installing a portable WTF to allow treated CSG water to be beneficially used all incur High and unacceptable risk scores associated with land disturbance. The options would require installation of the WTF as well as treated CSG water and brine storage tanks; and

- Options involving the transfer of CSG water from the Peat development area for treatment at another Australia Pacific LNG WTF incur High and unacceptable risks associated with the requirement for regular truck movements over a distance in excess of 100 km. Under these options, it is estimated that emissions of CO2 equivalents would exceed 1,300 Tonnes over a 20 year period.





5.2.5. Summary of the CSG Water Management Option Assessment

The assessment of CSG water management options for the Peat development area presented in this

CWMP shows that:

Untreated CSG water has the potential to be beneficially used by local project activities

undertaken by Australia Pacific LNG. The risks associated with this option are ranked as

Medium and considered acceptable when implemented alongside existing management

controls (outlined in Appendix A and Section 7).

There is no demand for CSG water from consulted landholders in the vicinity of key CSG

water management infrastructure. The risks of using untreated CSG water for agricultural

activities, aquifer injection, municipal supply, industrial supply, release to surface waters or

injection to a basement formation are High or Severe and therefore unacceptable;

The risks associated with all options that involve long-term treatment of CSG water by

Australia Pacific LNG are High and unacceptable. Furthermore, the capital and operating

costs of treating CSG water are prohibitive considering the small volumes of CSG water

forecast to be produced; and

Evaporation of CSG water at GPF Pond 2 represents an appropriate and environmentally

acceptable component of the CSG water management strategy for the Peat development

area and has been assessed as having a Low risk to EVs. By gathering CSG water to a single,

existing pond, CSG water can be effectively managed through the continued implementation

of existing control measures (outlined in Appendix A and Section 7).

On the basis of these findings, the revised CSG water management strategy for the Peat development

area is proposed as follows:

Gathering of CSG water to a single, lined, CSG water management pond (GPF Pond 2);

Local beneficial use of stored CSG water to support project activities undertaken by Australia

Pacific LNG;

Natural evaporation at GPF Pond 2 reflecting the regional climate; and

If required to manage unexpected increases in the volume of stored water such as those

associated with unexpected wet weather or unforeseen CSG water production, short-term

trucking of stored water for treatment and beneficial use in another Australia Pacific LNG

development area.

5.3. Implementing the Revised Strategy

Existing CSG water management infrastructure in the Peat development area consists of a HDPE pipeline

water gathering network linking CSG wells to one of five (5) CSG water management ponds. Evaporation

reduces the volume of water in these ponds and in addition, where appropriate, and in accordance with

the Peat EA, stored CSG water is also used for construction and dust suppression.

To transition this existing scheme to one which supports the revised CSG water management strategy

utilising one (1) CSG water storage pond as opposed to five (5), the following activities will be

completed:

Closed tank(s) will be installed at the site of Pond 12;

Pond 12 Cell 1, Pond 12 Cell 2 and Pond 32 will be decommissioned and the HDPE pipelines

linking these ponds to CSG wells will be connected to the closed tank(s);

GPF Pond 1 will be decommissioned and the HDPE pipelines linking this pond to CSG wells

will be connected to GPF Pond 2;

Pond 12 Cell 1, Pond 12 Cell 2, Pond 32 and GPF Pond 1 will be remediated in accordance

with a Transitional Environmental Program (TEP);





To allow for regular truck access, the road on public land linking Pond 12 to the sealed

public road and if required, the road on private land linking Pond 32 to the sealed public

road (that in turn provide access to the Peat GPF) will be upgraded;

Regular vehicle movements will be established to truck CSG water from the closed tank(s) to

GPF Pond 2;

Where feasible, CSG water stored at GPF Pond 2 or the closed tank(s) will be beneficially

used for local dust suppression and/or construction activities in accordance with the relevant

approval; and

Should unexpected wet weather or unforeseen CSG water production cause the volume of

stored CSG water in GPF Pond 2 to approach its maximum operating level (as specified in its

operational plan), CSG water will be trucked on a short-term basis for beneficial use in

another Australia Pacific LNG development area to safely manage pond water level.

The proposed CSG water management strategy is fully aligned to the CSG Water Management Policy

(DEHP 2012a) and addresses the conditions of the Peat EA (amended as proposed) by:

Discontinuing the use of multiple water storage ponds for primary CSG water management;

Decommissioning and remediating four (4) of the five (5) existing CSG water storage ponds;

Justifying natural evaporation as a component of CSG water management in the Peat

development area;

Prioritising feasible beneficial uses in the vicinity of extraction; and,

If required to manage higher than expected increases in CSG water storage, trucking stored

water to another Australia Pacific LNG beneficial use scheme.





6. CSG Water Management Scheme

This chapter of the CWMP describes the revised scheme for CSG water management in the Peat

development area.

6.1. CSG Water Production & Gathering

All CSG water produced in the Peat development area will initially be gathered via buried HDPE pipelines

to one (1) of the following CSG water storage facilities:

Closed tank(s) at site of Pond 12; or

Peat GPF Pond 2.

A small quantity of gas produced at the CSG wells is dissolved in the CSG water. As this CSG water passes

along the HDPE gathering pipelines, its pressure reduces and a proportion of the gas is liberated.

Automatic high point vents are installed along the HDPE pipeline to allow the accumulated gas to be

vented and thereby to prevent the interruption of flow.

In addition, low point drains are installed along the gas flowlines to remove any water that condenses

from the gas stream. These low point drains are manually operated with collected CSG water being

manually transferred to one of the CSG water storages. Water extracted from low point drains is not

released to land.

CSG water gathered to the closed tank(s) will be transferred by tanker to GPF Pond 2. Aggregating CSG

water to GPF Pond 2 allows four (4) of the five (5) existing CSG water storage ponds to be

decommissioned and remediated in accordance with a TEP to be submitted to DEHP in 2015.

6.2. CSG Water Storage

Australia Pacific LNG acknowledges the need to address Condition (D3) of the Peat EA (amended as

proposed). To establish a schedule for efficiently achieving this objective, Australia Pacific LNG will

submit a TEP to DEHP in 2015. This TEP will outline the component tasks and milestone dates associated

with decommissioning and remediating Pond 12 Cell 1, Pond 12 Cell 2, Pond 32 and GPF Pond 1.

As an initial activity, during 2015, closed tank(s) will be installed at the site of Pond 12. The existing

HDPE pipelines connecting CSG wells to this pond will be disconnected and re-routed to the closed

tank(s). CSG water previously gathered to Pond 32 will be gathered by the existing pipeline network to

the closed tank(s) at the site of Pond 12.

CSG water gathered to the closed tank(s) at the site of Pond 12 will then be trucked to GPF Pond 2 via

regular vehicle movements at a frequency dependent on the rate of CSG water inflow. Table 6-1 below

provides anticipated truck movements based on current tank designs and predicted CSG water inflows.

The stored level in closed tank(s) will undergo regular visual inspection by field operators.

GPF Pond 1 will be decommissioned and the HDPE pipeline connecting it to CSG wells will be connected

to GPF Pond 2. Pond 12 Cell 1, Pond 12 Cell 2, Pond 32 and GPF Pond 1 will then be remediated in

accordance with the TEP.

Table 6-1: Summary Water Balance for Closed Tanks

Storage

Individual

Tank

Operating

Capacity (ML)

CSG Water

Inflow in

May 2014

(ML/d)

Inflow

Assumed for

Tank Design

(ML/d)

Individual Tank

Capacity at

Design Inflow

(Days)

Approximate

Frequency of Truck

Movements at

Design Inflow A

Closed Tank (s) at

site of Pond 12 0.035 0.0008 0.01 3.5

One trip every 1 to 2

days

Table Notes A Assuming use of a 10,000 L tanker.





6.3. CSG Water Use

In order to reduce demand on regional water sources, wherever practical, Australia Pacific LNG will

prioritise the beneficial use of CSG water to support project activities. The suitability of using stored

CSG water (either stored in the closed tanks or in GPF Pond 2) for dust suppression and/or construction

will be determined on a case-by-case basis dependent on the volume and quality of the water required

and the volume and quality of the CSG water stored. The Peat EA specifies current requirements for the

use of CSG water for dust suppression and construction including water quality limits, required water use

and monitoring procedures, and notification obligations.

Should actual rates of CSG water production or extreme wet weather cause the stored volume to

approach the maximum operating level of GPF Pond 2 (as specified in its operational plan), Australia

Pacific LNG will implement the trucking of stored CSG water to one or more of the existing Australia

Pacific LNG beneficial use schemes (see Table 5-9). The choice of which scheme to supply will be made

with the aim of optimising:

Best use of available capacity at WTFs;

Optimising the extent to which beneficial use demands for treated water from the various

facilities can be met; and

Minimising trucking distance and the social impact of truck movements on the community.

6.4. Management of Saline Waste

The evaporation of a proportion of the CSG water in GPF Pond 2 will act to increase the salinity of the

remaining stored water. At the end of the lifetime of the Peat development area, any saline residue in

GPF Pond 2 will be managed in accordance with the Peat Rehabilitation Plan (Q-8100-15-MP-005) and

will give due consideration to the DEHP prioritisation hierarchy and the waste and resource management

hierarchy. Saline residue within Pond 12 Cell 1, Pond 12 Cell 2, Pond 32 and GPF Pond 1 will be managed

in accordance with the TEP.

Should any CSG water in the Peat development area be transferred to another Australia Pacific LNG

development area for beneficial use, it is likely to undergo treatment thereby generating treated CSG

water and brine (unless it can be used beneficially in an untreated form). The brine generated as a

result of this treatment process will be managed in accordance with the EA and CWMP of the

development area in question (as referenced in Table 5-9).





7. Risks, Potential Impacts and Management

7.1. Risk Assessment

Australia Pacific LNG has conducted a risk assessment of the existing and proposed CSG water

management schemes, applying the Australia Pacific LNG risk matrix presented in Figure 5-5.

All identified risks are recorded in the Origin Collective Intelligence System (OCIS) and are reviewed at a

frequency dependent on their risk level. ‘Low’ and ‘Medium’ level risks are reviewed annually, ‘High’

risks are reviewed twice a year and ‘Severe’ and ‘Extreme’ risks are reviewed monthly.

7.2. Residual Risks and Additional Mitigation Measures

7.2.1. Existing CSG Water Management Scheme

Table 7-1 shows that with controls in place, all except one of the identified risks associated with the

existing CSG water management scheme is of a ‘Low’ level and is therefore considered acceptably

managed without further treatment.

The risk of an uncontrolled release or seepage of CSG water from an unlined CSG water storage pond is

considered a ‘Medium’ level risk. Ongoing monitoring of shallow groundwater quality in the vicinity of all

existing CSG water management ponds (most recently reported in September 2013) has found no

exceedances of trigger levels that might otherwise indicate a potential for environmental harm.

Notwithstanding this observation, Australia Pacific LNG will decommission and remediate Pond 12 Cell 1,

Pond 12 Cell 2, Pond 32 and GPF Pond 1 in accordance with the TEP to be submitted to DEHP in 2015.

7.2.2. Revised CSG Water Management Scheme

Table 7-2 shows that with proposed standard controls in place, all identified risks associated with the

ongoing use of GPF Pond 2 as an evaporation pond are ranked as ‘Low’ and are therefore considered

acceptably managed without further controls.

The risk of an uncontrolled release or seepage of CSG water from a CSG water storage pond is assigned a

‘Low’ risk level for the revised CSG water management scheme. This reflects the fact that CSG water

will be stored at a single, HDPE-lined storage pond (as opposed to storage at five (5) ponds under the

existing CSG water management scheme) and is further justified by the outputs of water balance

modelling that indicate that GPF Pond 2 has a storage capacity that significantly exceeds the predicted

combined CSG water inflow and net evaporation (see Figure 5-4).

Australia Pacific LNG conducts regular monitoring of the condition and integrity of all ponds in

accordance with a series of standard procedures (specified in Section 9). Should monitoring indicate the

need for future repair work to GPF Pond 2, stored water will be transferred to a temporary tank and

trucked to one or more of the existing Australia Pacific LNG beneficial use schemes (see Table 5-9)

whilst repairs are being undertaken.

The revised scheme also includes beneficial use by Australia Pacific LNG Project activities where

possible, an activity that incurs a Medium risk to EVs due to the need to truck CSG water to the local

beneficial use. This risk is considered be to appropriately managed by existing control measures and is

therefore accepted in accordance with the Risk Management Directive (ORG-RISK-DVE-001).





Table 7-1: Risk Assessment for Existing CSG Water Management Scheme

Ref. Risk Potential Cause Existing Controls Consequence Likelihood Risk Level

1

Uncontrolled release

of CSG water from

gathering network

adversely impacts

surface water,

groundwater and/or

soil EVs.

Loss of pipeline

integrity

Pipelines designed in accordance with Australian Standards by

suitably qualified engineers.

Low point drains manually operated with collected CSG water

transferred to the CSG water storages.

Visual inspection of pipeline route.

1

MINOR

2

HIGHLY UNLIKELY

LOW

2


or seepage of CSG

water from CSG

water storage ponds

adversely impacts

surface water,

groundwater and/or

soil EVs.

Failure of pond

liner

Unlined pond

Poor

construction

and / or

operation

Extreme

rainfall causes

volume stored

to exceed pond

capacity and /

or promote

scour of

embankments

Monitoring as outlined in the Dam and Pond Inspection Guide

(OEUP-INT1000-GDL-ENG-021).

Operator training in Standard Operating Procedures, Critical

Operating Procedures and Emergency Response Procedures.

Peat Produced Water Storage Facility Groundwater Monitoring

Plan (OEUP-Q8100-PLN-ENV-002) used to identify any evidence of

seepage.

HDPE pond lining in place at GPF Pond 1 and GPF Pond 2.

2

MODERATE

3

UNLIKELY MEDIUM

3

Application of CSG

water for dust

suppression /

construction

adversely impacts

surface water,

groundwater and/or

soil EVs.

Oversupply /

inappropriate

application of

water

Water supply and use in accordance with Peat EA.

Supervision of water application and use of appropriate spray

equipment to prevent ponding or runoff.

CSG water quality sampled when required and reviewed prior to

application to confirm it meets water quality standards.

Where CSG water is used for dust suppression and/or construction,

the application rate is controlled to avoid ponding or runoff.

No application of water during rainfall events.

1

MINOR

3

UNLIKELY LOW





Table 7-2: Risk Assessment for Revised CSG Water Management Scheme

Ref. Risk Potential Cause Proposed Standard Controls Consequence Likelihood Risk Level

1


of CSG water from

gathering network

adversely impacts

surface water,

groundwater and/or

soil EVs.

Loss of pipeline

integrity

Pipelines designed in accordance with Australian Standards by

suitably qualified engineers.

Low point drains manually operated with collected CSG water

transferred to the CSG water storages.

Visual inspection of pipeline route.

1

MINOR

2

HIGHLY UNLIKELY

LOW

2


of CSG water from

tanks adversely

impacts surface

water, groundwater

and/or soil EVs.

Failure of tank

Overflow of

tank

Poor

construction

and / or

operation

Tanks closed to prevent rainfall entry.

All tanks designed, supplied, installed, tested and commissioned

in accordance with applicable Australian Standards.



1

MINOR

3

UNLIKELY LOW

3


or seepage of CSG

water from CSG

water storage pond

adversely impacts

surface water,

groundwater and/or

soil EVs.

Failure of pond

liner

Poor

construction

and / or

operation

Extreme

rainfall causes

volume stored

to exceed pond

capacity and /

or promote

scour of

embankments

Monitoring as outlined in the Dam and Pond Inspection Guide

(OEUP-INT1000-GDL-ENG-021).



Peat Produced Water Storage Facility Groundwater Monitoring

Plan (OEUP-Q8100-PLN-ENV-002) used to identify any evidence of

seepage.

Reduction in number of storage ponds from five (5) to one (1).

HDPE pond lining in place at retained pond (GPF Pond 2).

BoM weather forecasts used to optimise available storage capacity

and to forewarn and plan for any need to truck stored water to

alternative storage facilities or other Australia Pacific LNG

development areas.

Water balance modelling used to assess available storage capacity

considering predicted CSG water production and historic climate.

2

MODERATE

2

HIGHLY UNLIKELY

LOW





Ref. Risk Potential Cause Proposed Standard Controls Consequence Likelihood Risk Level

4

Application of CSG

water for dust

suppression /

construction

adversely impacts

surface water,

groundwater and/or

soil EVs.

Oversupply /

inappropriate

application of

water

Water supply/use in line with Peat EA or BUA as appropriate.

Supervision of water application and use of appropriate spray

equipment to prevent ponding or runoff.

CSG water quality data will be sampled when required and

reviewed prior to application to confirm it meets water quality

standards. Records will be retained for auditing purposes.

Where CSG water is used for dust suppression and/or construction,

the application rate for water will be monitored to avoid ponding

or runoff from the application area.

Application of water will not occur during rainfall events.

1

MINOR

3

UNLIKELY LOW

5

Trucking to

beneficial use results

in air emissions from

fuel consumption and

minor social

disruption

Truck

movements to

supply water to

Australia Pacific

LNG Project

activities

Vehicle selection requirements specified in Land Transport

Directive (ORG-HSE-DVE-001).

Procedures implemented by all drivers to ensure safe vehicle

movements specified in Land Transport Directive (ORG-HSE-DVE-

001) and Fatigue Risk Management Directive (ORG-HSE-DVE-043).

1

MINOR

6

ALMOST CERTAIN

MEDIUM

6

Vehicle

incident/accident

leads to spill of CSG

water and resultant

adverse impact on

surface water,

groundwater and/or

soil EVs.

Driver error

Poor road

condition

Poor weather

Poor vehicle

condition

Collision with

wildlife/stock

Land Transport Directive (ORG-HSE-DVE-001) and Fatigue Risk

Management Directive (ORG-HSE-DVE-043) implemented.

All drivers to complete safe driver training.

All heavy vehicles fitted with In-Vehicle Monitoring System.

Driver to inspect vehicle prior to use using Inspection Checklist.

Fatigue Risk Management Plan approved and implemented.

All journeys managed via one of the following means:

Implementation of a Journey Management Plan lodged by phone,

in advance, with the national response centre (1800 132 771); or

Implementation of relevant standard operating procedure to

include a comprehensive risk assessment.

Vehicle Safety Checklists and Journey Management Plans provided

to site manager or business unit manager for record maintenance.

Driver to check with site superintendent during periods of wet

weather to confirm roads are safe.

1

MINOR

1

REMOTE LOW





8. Management Criteria

In accordance with the EP Act, Australia Pacific LNG has developed measurable criteria (termed

management criteria) against which the effectiveness of CSG water management in the Peat

development area will be monitored. Table 8-1 presents the management criteria for the Peat

development area, each of which consists of:

A management objective for protecting EVs from the potential impacts of the CSG water

management activity;

A series of tasks to ensure the objective is achieved; and

Specific indicators and targets against which the performance of CSG water management can

be measured, assessed and audited in an objective and repeatable manner.

The continued suitability of all management criteria and operational performance against each criterion

will be regularly evaluated and reported once a year in the annual return to the Peat EA. If it is found

that a management criterion has not been met, the following activities will be undertaken:

Investigate significance of failure to meet management criterion on EVs and identify likely

cause/s;

Where cause/s can be attributed to the activities of Australia Pacific LNG, identify means to

refine operating procedures in order to ensure that the criterion is met in future;

Where required in order to protect and maintain EVs, implement any recommended changes

to operating procedures for CSG water management.

The Peat EA annual return will outline the results of the above activities where they are required.

Peat Coal Seam Gas Water Management Plan




Table 8-1: Management Criteria for the Peat Development Area

Objective Task Performance Criteria Performance Target

1 - No unauthorised

disturbance of

environmentally

sensitive areas due

to CSG water

management

activities.

Comply with disturbance allowances in Peat EA.

Disturbance approvals secured through

implementation of Disturbance Procedure (OEUP-

Q1000-PRO-ENV-001).

For all relevant activities, ensure that Environmental

Constraints Assessment - Preparation and Issue (Q-

LNG01-15-AW-0014) is followed.

Monitor the condition of Commonwealth and

Queensland State listed species and communities and

endangered regional ecosystems in accordance with

Environmental Constraints Planning and Field

Development Protocol (Q-LNG-15-MP-0109).

Develop and implement an approved Cultural Heritage

Management Plan.

Records of environmental constraints

assessments and evaluation of

compliance against Disturbance

Procedure (OEUP-Q1000-PRO-ENV-

001).

Extent of unauthorised disturbance of

environmentally sensitive areas.

Full compliance with Disturbance

Procedure (OEUP-Q1000-PRO-ENV-001)

and Environmental Constraints

Assessment - Preparation and Issue (Q-

LNG01-15-AW-0014) demonstrated

through records stored on Disturbance

Tracker intranet site.

Zero unauthorised disturbance of

environmentally sensitive areas.

2 - No unauthorised

releases to the

environment from

the CSG water

gathering network.

Implement an Operations and Maintenance Plan for

the gathering network. Ensure this plan addresses the

operation of valves, low point drains, high point vents

and pipeline leak detection and isolation procedures.

Respond to all incidents in accordance with LNG

Environmental Incident Procedure (OEUP-Q1000-PRO-

ENV-006).

Volume of unauthorised leaks or spills

from pipelines.

Records of incidents, investigations

and close out processes.

Zero unauthorised leaks or spills from

pipelines.

Zero OCIS incidents with overdue

actions.

3 - No unauthorised

releases to the

environment from

non-regulated

structures.



ENV-006).

Volume of unauthorised releases from

tanks.



Zero unauthorised releases from tanks.


actions.





Objective Task Performance Criteria Performance Target

4 - No unauthorised

releases to the

environment from

regulated structures.

Maintain register of regulated structures.

Develop and implement a Groundwater Monitoring

Plan to identify potential seepage from ponds.

Implement monitoring program as outlined in the Dam

and Pond Inspection Guide (OEUP-INT1000-GDL-ENG-

021).



ENV-006).

Volume of unauthorised releases from


Change in groundwater quality.

Records demonstrating compliance

with implementation of Dam and Pond

Inspection Guide (OEUP-INT1000-GDL-

ENG-021).



Zero unauthorised releases from


No exceedance of trigger value

specified in relevant Groundwater

Monitoring Plan attributable to

management of regulated structures.

Records of compliance with Dam and

Pond Inspection Guide (OEUP-INT1000-

GDL-ENG-021).


actions.

5 - Take all

reasonable steps to

evaluate and, where

appropriate,

implement means to

optimise CSG water

management.

Develop and maintain a numerical reservoir model to

predict the quantity of CSG water production over the

life of the development area.

Continue to investigate opportunities to improve CSG

water management and prioritise options in

accordance with the CSG Water Management Policy

(DEHP 2012a).

Evidence that performance of CSG

water management system is

continually assessed and that, where

required, alternative means to

optimise the system are investigated.

Report on the outcomes of

investigations to optimise CSG water

management activities in each Peat EA

annual return.

6 - Supply CSG water

to beneficial uses in

accordance with

Peat EA or relevant

BUA.

Ensure Peat EA or BUA requirements for use in

question are met.

Develop and implement Water Quality Monitoring

Program to demonstrate that water quality is fit for

use, where water quality limits are stipulated.



ENV-006).

Water supplied and used in

accordance with Peat EA or relevant

BUA conditions.

Monitoring programs developed to

effectively monitor potential impacts

to EVs from beneficial uses.


and close-out processes.

No non-compliance with Peat EA or

relevant BUA conditions for beneficial

uses.

Water Quality Monitoring program

implemented by commencement of

beneficial use activities.


actions.





9. Monitoring

This chapter of the CWMP describes the monitoring that will be undertaken in the Peat development

area to enable the prediction and early detection of potential impacts to EVs from CSG water

management.

In addition to the groundwater and storage pond monitoring described below, closed tank(s) will be

regularly inspected by field operators to manage levels and to ensure an appropriate trucking frequency.

9.1. Integrity of CSG Water Storage Ponds

Australia Pacific LNG implements a range of inspection and monitoring procedures, summarised in Table

9-1, in order to ensure the continued safety and structural integrity of its CSG water storage ponds.

Table 9-1: CSG Water Storage Pond Monitoring Requirements

Activity Frequency Reporting Responsibility Procedure

Monitoring requirements

Embankments At least annually or

as required by the

Dam Inspection

Schedule (A-1000-20-

PS-001)

Any detectable movement

recorded as an incident in

OCIS and reported in

accordance with Peat EA

Qualified surveyors Asset Integrity

Management Plan for

Dams (Q1000-PLN-

ENG-002)

Pond water level Half yearly For inclusion in annual

return

Operations staff Dam and Pond

Inspection Guide

(OEUP-INT1000-GDL-

ENG-021)

Inspection requirements

Compliance

inspection

Annually Inspection report to be

submitted to Queensland

Government in

accordance with Peat EA

Registered

Professional Engineer

of Queensland

Procedure for

Conducting Annual and

Comprehensive Dam

Inspections (A-1000-

20-AP-001)

Embankments

(cracking,

erosion, seepage,

subsidence and

settlement, liner

damage)

Monthly or following

significant rainfall

For inclusion in annual

inspection report

Operations staff Dam and Pond

Inspection Guide

(OEUP-INT1000-GDL-

ENG-021)

Documentation Requirements

Register of

regulated

structures

Maintain existing

records

For inclusion in annual

return

Operations staff In accordance with

Peat EA

9.2. Groundwater

Groundwater monitoring in the Peat development area is targeted at the identification of potential

seepage from CSG water storage facilities. The groundwater monitoring program therefore includes two

(2) components, as outlined in the Peat Produced Water Storage Facility Groundwater Monitoring Plan

(OEUP-Q8100-PLN-ENV-002):

1. Monitoring of shallow groundwater at bores located around CSG water storage facilities; and

2. Monitoring of stored water quality.





The Peat Produced Water Storage Facility Groundwater Monitoring Plan (OEUP-Q8100-PLN-ENV-002) lists

the parameters to be monitored in groundwater and stored water in ponds as well as monitoring

locations and the procedures to be followed during sample collection and analysis. The monitoring

program has been developed to meet the requirements of:

Schedule C of the Peat EA;

The DEHP Monitoring and Sampling Manual 2009;

Geoscience Australia (2009) Groundwater Sampling and Analysis - A Field Guide;

AS/NZS 5667 11 2009 Water Sampling Guidelines - Part 11 Guidance on sampling

groundwater; and

National Environmental Protection (Assessment of Site Contamination) Measures (Australian

Government 1999).

Groundwater parameters will be monitored biannually with the exception of standing water level which

will be monitored quarterly. Stored water samples will be taken annually with parameters mirroring

those for groundwater.

The interpretation and assessment of results shall be performed by a suitably qualified professional, and

shall be compared to trigger values. If a trigger value is exceeded, a phased investigation will be

implemented in accordance with the Peat Produced Water Storage Facility Groundwater Monitoring Plan

(OEUP-Q8100-PLN-ENV-002) and the LNG Environmental Incident Procedure (OEUP-Q1000-PRO-ENV-006).

9.3. CSG Water Use

All uses of CSG water will comply with relevant approvals, including the collection, analysis and

reporting of data where required.

Wherever practicable, Australia Pacific LNG will use CSG water for dust suppression and construction

activities. The Peat EA currently specifies requirements for the use of CSG water for these activities

including water quality monitoring obligations (see Table 9-2). In addition, the use of CSG water for dust

suppression and/or construction must be carried out in such a way as to ensure that:

Vegetation is not damaged;

Soil erosion and soil structure damage is avoided;

The quality of groundwater is not adversely affected;

There is no water runoff from the nominated discharge areas;

There is no surface ponding or CSG water; and

There are no releases of CSG water to any surface waters

Approval of the use of CSG water for dust suppression and construction activities is currently authorised

by the Peat EA but in future, may be transitioned to the General BUA (DEHP 2014a). Any transition will

be described in an update to this CWMP, and implemented in accordance with approval processes.

Table 9-2: Peat EA Water Quality Limits for Dust Suppression and Construction Activities

Parameter Unit Limit Limit Type

pH - 6 - 9 Range

Total dissolved solids mg/L 2,000 Maximum

Total petroleum hydrocarbons mg/L 10 Maximum

9.4. Decommissioning and Remediation

Decommissioning and remediation of Pond 12 Cell 1, Pond 12 Cell 2, Pond 32 and GPF Pond 1 will be

undertaken in accordance with the TEP to be submitted to DEHP in 2015.





10. Management Systems and Records

The following chapter describes the key management systems through which this CWMP will be implemented.

10.1. Health, Safety and Environment Management System

Australia Pacific LNG operates under a health, safety and environment (HSE) policy and an established

Health, Safety and Environment Management System (HSEMS) developed with reference to

Australian/New Zealand Standard ISO 14001 - Environmental Management Systems and AS 4801 -

Occupational Health and Safety Management Systems. The HSEMS is implemented through a continuous

improvement cycle of Commit Plan Do Check Review. Each element of the cycle is executed

through a set of standards and directives, all of which support the HSE policy.

10.2. Project Delivery Process

The project delivery process (PDP) represents a structured and transparent project management process

with the aim of:

Identifying and assessing alternative options;

Selecting and developing the highest performing option/s;

Effectively implementing and executing the project; and

Providing reliable operation of all assets.

Whilst the PDP mandates the completion of specific activities, the means of achieving these

requirements are flexible to site-specific factors. The PDP has the following characteristics:

It addresses the full lifecycle of the project with each project progressing through a series of

controlled phases that include a formal decision review at the end of each phase;

Projects only progress through a decision gate after detailed scrutiny of their risks, assurance

having been provided that these risks can be effectively managed;

Controlled delivery is assured by having the need to meet defined objectives and targets

agreed early with the project manager and key stakeholders;

The organisational structure supports the delivery of projects via a sufficiently multi-

functional resource base throughout its lifecycle; and

Continuous improvement and performance measurement are built in to each PDP phase.

10.2.1. Environmental Data Management System

ESdat, an environmental data management system, has been selected by Australia Pacific LNG as the

internal database for the storage of all laboratory-derived water quality data. ESdat allows for the

management of data, supports trend analysis and provides a systematic approach to record keeping in

order to ensure ongoing data integrity. All ESdat records will be retained for no less than 5 years.

10.2.2. Exploration and Production Operations Management System

The Exploration and Production Operations Management System (EPOMS) provides the framework for

storing, accessing and using documentation applicable to the operation of infrastructure in the Peat

development area, including the CSG water management system.

10.2.3. Enterprise Asset Management System

Australia Pacific LNG has developed a register to capture all CSG operational assets. This data is stored

in the Enterprise Asset Management System (EAMS) and is used to schedule routine tasks against

particular assets. EAMS also tracks actions with respect to scheduled and reactive asset maintenance.





10.2.4. Origin Collective Intelligence System

Factual and accurate accounts of all incidents are recorded in OCIS, an incident and risk management

database. OCIS provides a common platform for reporting incidents, observations, risks and any relevant

or stand-alone actions. It is used to track incident investigation, reporting requirements and

preventative and/or corrective actions. As the investigation and associated actions are completed, the

incident can be reviewed and closed out. Incident reports are stored in OCIS for no less than the life of

the project or activity.

10.2.5. ATLAS Compliance Reporting and Recording System

ATLAS is an integrated environmental, social and regulatory compliance system that provides Australia

Pacific LNG with the capacity to record:

Regulatory compliance conditions and environmental and social commitments;

Required actions with due dates and assigned actions to defined users; and

Evidence of compliance.

ATLAS is used to record and track compliance against all EA conditions.

10.3. Risk Registers

For each operational site, a register documenting reasonably expected environmental risks is

maintained. Each risk register is reviewed annually and updated to reflect any changes in operating

philosophy.

Populated risk registers are uploaded to OCIS along with any actions for tracking. Completion of actions

under an agreed treatment plan will prompt a review of the risk register.

10.4. Roles and Responsibilities

The development, implementation and continual improvement of this CWMP is reliant on an effective

communication program. Personnel responsible for the implementation of this CWMP are identified in

Appendix B.

As part of the HSEMS, Australia Pacific LNG has developed company-wide systems and processes which

identify relevant stakeholders, staff and contractors and the required training and competencies

necessary to undertake their job roles. The communication of this CWMP applies to all staff involved in

CSG water management in the Peat development area and is delivered in a face-to-face environment

using the Australia Pacific LNG training and competency systems. Personnel are deemed to be a

Competent Person after completing the required combination of theoretical and practical training,

education and experience modules and after having been assessed by Competence Assessors. A training

and competency register is maintained for the life of the project.





11. Response and Reporting

11.1. Routine

An annual return will be submitted to DEHP to demonstrate how relevant Peat EA conditions have been

met for the preceding year. This will include a review of performance against the management criteria

presented in Section 8. In addition, other routine reporting associated with this CWMP will include:

An annual monitoring report in accordance with Condition (P5) of the Peat EA to be compiled

and presented to DEHP upon request; and

An annual monitoring and compliance report in accordance with Condition (D10) of the Peat

EA to be submitted to DEHP with the annual return and on request.

This CWMP is also subject to periodic review and update, with audit reports and actions stored and

tracked through OCIS. Audit records will be kept for no less than five (5) years and in accordance with

the relevant regulatory and legislative requirements.

11.2. Non-routine

The Peat development area operates under two (2) key Australia Pacific LNG directives; the Crisis and Emergency Management Directive (ORG-HSE-DVE-003) and the Incident Management Directive (ORG-HSE-DVE-006).

The Crisis and Emergency Management Directive (ORG-HSE-DVE-003) defines requirements for the effective response to a crisis and emergency situation in order to minimise the impacts on people, environment, plant and/or property. The emergency response framework contains three (3) tiers based on the severity of the potential impact:

Serious – managed under a site emergency response plan;

Critical or Major – managed under a group emergency management plan; and

Catastrophic – managed under a crisis management plan.

A site-specific Emergency Response Plan: Peat Gas Plant and Field (OEUP-Q8100-PLN-SAF-002) outlines specific emergency responses for the Peat development area including those related to environmental incidents.

The Incident Management Directive (ORG-HSE-DVE-006) details the internally-specified mandatory response, notification, recording, investigation, corrective and preventative actions, review, and analysis and reporting requirements for all incidents. There are six (6) stages in the incident management process as follows:

Stage 1 – Response and notification;

Stage 2 – Incident recording;

Stage 3 – Incident investigation;

Stage 4 – Corrective and preventive actions;

Stage 5 – Incident sign-off; and

Stage 6 – Review, analysis and reporting.

All incidents in the Peat development area are responded to in accordance with the LNG Environmental

Incident Procedure (OEUP-Q1000-PRO-ENV-006). All incident response processes are recorded and closed

out through OCIS with incident reports stored for no less than the life of the project.

All monitoring results will be reviewed regularly and on an ongoing basis. Non-compliance or exceedance

of conditions in the Peat EA will be reported within the required timeframe to the appropriate authority.





12. Review and Update of the CSG Water Management Strategy

Australia Pacific LNG is committed to regularly revisiting its CSG water management strategies in order

to:

Evaluate whether the strategies remain capable of managing the total volumes of CSG water

expected to be produced over the lifetime of the development area;

Identify whether the implemented options of managing CSG water can be optimised; and

Establish whether new or alternative CSG water management options are required and if so,

whether or not they are feasible.

Review and update of the Peat CWMP will be undertaken once every three (3) years and in accordance

with Condition (D8) of the Peat EA and will include consideration of:

Current strategies;

Best practice alternatives;

Advances in new technology;

Standards and practices in relation to the management of CSG water;

New beneficial use proposals; and

Management of waste streams.

An update to the CWMP may also be triggered by:

Any appropriate and relevant recommendations from the Peat EA annual return;

Failure to meet the management criteria outlined in Section 8;

Any significant change to the predicted CSG water production profile;

Any significant change to the understanding of CSG water quality;

Implementation of a new management practice not already addressed by the CWMP

(including additional beneficial uses of CSG water);

Any appropriate and relevant recommendations resulting from an incident investigation;

Any appropriate and relevant recommendations resulting from review of monitoring

results/data;

A request by the administering authority; and

Any significant change to relevant legislation and/or government policy.

Any changes to the Peat CWMP will be made in consultation with DEHP and relevant key stakeholders.

This framework for review and update is based on the continuous improvement methodology of Plan

Develop Evaluate Implement Monitor. In applying the continuous improvement cycle to this

CWMP, evaluation of performance against the management criteria outlined Section 8 acts as the key

metric for success.





13. References

AECOM, 2014. Environmental Site Assessment Report: Peat 12, Peat 32 and Peat GPF Dams, AECOM,

Australia.

ANZECC & ARMCANZ, 2000. Australian and New Zealand Guidelines for Fresh and Marine Water Quality,

ANZECC & ARMCANZ, Australia and New Zealand.

Acqua Della Vita Pty Ltd, 2014. Condamine River – DTA of boron and treated CSG water, Australia Pacific

LNG, Australia.

Australian Government, 2015. National Greenhouse and Energy Reporting [Online]. Available:

http://www.cleanenergyregulator.gov.au/National-Greenhouse-and-Energy-

Reporting/Pages/default.aspx, Accessed: 30 March 2015.

Australian Government, 1999. National Environmental Protection (Assessment of Site Contamination)

Measures, Australian Government, Canberra.

Australia Pacific LNG, 2010. Australia Pacific LNG Project Environmental Impact Statement, Australia

Pacific LNG, Australia.

Cockatoo Coal Ltd, 2012. North Surat – Taroom Project: initial advice statement, Cockatoo Coal Ltd.,

Australia.

Commonwealth of Australia, 1999. Environment Protection and Biodiversity Conservation Act.

Geoscience Australia, 2009. Groundwater Sampling and Analysis - A Field Guide, Australian Government,

Canberra.

Halcrow Pacific Pty Limited, 2012. Dawson River Release Scheme Direct Toxicity Assessment, Santos

GLNG Project, Australia.

National Health and Medical Research Council and Natural Resource Management Ministerial Council,

2011. Australian Drinking Water Guidelines, Australian Government, Canberra.

Northern Energy Corporation Limited, 2012. Elimatta Project: Environmental Impact Statement.

Northern Energy Corporation, Australia.

Natural Resource Management Ministerial Council, 2009. Australian Guidelines for Water Recycling:

Managed Aquifer Recharge, NRMMC, Australia.

National Uniform Drillers Licensing Committee, 2012. Minimum Construction Requirements for Water

Bores in Australia, National Uniform Drillers Licensing Committee, Australia.

Queensland Government Department of Environment and Heritage Protection, 2014a. General Beneficial

Use Approval Associated Water (including coal seam gas water), DEHP, Brisbane.

Queensland Government Department of Environment and Heritage Protection, 2014b. General Beneficial

Use Approval Irrigation of Associated Water (including coal seam gas water), DEHP, Brisbane.

Queensland Government Department of Environment and Heritage Protection, 2013a. Environmental

Protection Act 1994 Guideline: Application requirements for petroleum activities, DEHP, Brisbane.

Queensland Government Department of Environment and Heritage Protection, 2013b. Manual for

Assessing Consequence Categories and Hydraulic Performance of Structures, DEHP, Brisbane.

Queensland Government Department of Environment and Heritage Protection, 2012a. CSG Water

Management Policy, DEHP, Brisbane.

Queensland Government Department of Environment and Heritage Protection, 2012b. Manual for

Assessing Hazard Categories and Hydraulic Performance of Dams, DEHP, Brisbane.

Queensland Government Department of Environment and Heritage Protection, 2011. Environmental

Protection (Water) Policy 2009 – Dawson River Sub-basin Environmental Values and Water Quality

Objectives: Basin No. 130 (part), including all waters of the Dawson River Sub-Basin except the Callide

Creek Catchment, DEHP, Brisbane.

Queensland Government Department of Environment and Heritage Protection, 2009. Monitoring and

Sampling Manual, DEHP, Brisbane.

Queensland Government Department of Natural Resources and Mines, 2014. Minimum Standards for the

Construction and Reconditioning of Water Bores That Intersect the Sediments of Artesian Basins in

Queensland, DNRM, Brisbane.





Queensland Government Department of Natural Resources and Mines, 2013. Code of Practice for

Constructing and Abandoning Coal Seam Gas Wells and Associated Bores in Queensland, DNRM, Brisbane.

Queensland Government Department of Natural Resources and Mines, 2012. Great Artesian Basin

Resource Operations Plan, DNRM, Brisbane.

SMEC, 2014. Annual Dam Inspection, SMEC, Australia.

Stanmore Coal, 2011. The Range Project – Initial Advice Statement. Stanmore Coal, Australia.

State of Queensland, 2011. Waste Reduction and Recycling Act.

State of Queensland, 2009. Environmental Protection (Water) Policy.

State of Queensland, 1994. Environmental Protection Act.

State of Queensland, 1992. Nature Conservation Act.

State of Queensland, 1971. State Development and Public Works Organisation Act.

SunWater, 2015. Woleebee Creek-Glebe Weir – Overview [Online]. Available:

http://www.sunwater.com.au/future-developments/woleebee-creek-glebe-weir/overview. Accessed: 30

March 2015.

Xstrata Coal, 2012. Wandoan Project: Fact Sheet – water management. Xstrata Coal, Australia.

Xstrata Coal, 2009. Wandoan Coal Project: Supplementary Environmental Impact Statement. Xstrata

Coal, Australia.





Appendix A - Assessment of Risks to Environmental Values





















Appendix B - Responsibilities for CSG Water Management

Role Responsibility

Supervisor - Peat Conducts on-site inductions, toolbox talks and training as required.

Ensures day-to-day activities comply with the requirements of the Peat EA, other

applicable regulatory approvals and the CWMP.

Supervisors on-site water quality and quantity monitoring as required.

Notifies Superintendent – Talinga/Orana of any incidents that have the potential to cause

environmental harm.

Ensures all environmental incidents and hazards are recorded in accordance with

relevant Australia Pacific LNG procedures.

Complies with all relevant occupational health, safety and environmental legislation,

codes of practice, standards, policies, operating procedures and work instructions.

Is actively involved in developing, reviewing and auditing the CWMP and procedures.

Superintendent –

Talinga/Orana

Overall responsibility for ensuring CSG water management is conducted in accordance

with Peat EA.

Ensures appropriate communication with stakeholders to ensure they are informed of

issues and developments that may affect their day-to-day activities.

Ensures all environmental incidents and hazards are recorded in accordance with

relevant Australia Pacific LNG procedures.

Complies with all relevant legislations, codes of practice, standards, policies, operating

procedures and work instructions.

Production Chemist Provides technical advice and assistance for water quality monitoring required by Peat

EA and CWMP.

Provides technical advice and assistance to ensure all monitoring is undertaken by

suitably qualified and competent personnel in accordance with regulatory / legislative

requirements.

Reviews verification monitoring laboratory results upon delivery and uploads these to

ESdat.

Ensures non-compliances are escalated in accordance with Australia Pacific LNG

procedures.

Asset Manager –

Talinga/Orana

Accountable for the development of specific operations and maintenance plans and

procedures in consultation with key stakeholders and project personnel to ensure

efficient operation of CSG water management infrastructure.

Initiates any required incident investigations, reviews investigation outcomes and ensures

mitigation actions are implemented.

Provides managerial support for the reviewing, reporting, auditing, monitoring and

training requirements of the CWMP.

Provides resources with respect to optimising operations to meet the objectives set out

in the CWMP.

Provides resources to support non compliance investigations.

Co-ordinates and schedules annual review of risk register.

Is actively involved in developing, reviewing and auditing health, safety and environment

systems and procedures.





Role Responsibility

Productions

Operations Group

Manager

Ensures appropriate resources are allocated to ensure that management of CSG water

complies with applicable Australia Pacific LNG policies, procedures and CWMP

requirements.

Ensures that the commitments of the CWMP are implemented and ensures monitoring,

recording and reporting are undertaken.

Ensures that appropriate communication systems are in place between Australia Pacific

LNG, contractors and other stakeholders that may affect their day-to-day activities.

Environmental

Approvals and

Strategy Manager

Liaises with regulatory authorities, key stakeholders and Australia Pacific LNG employees

and contractors with respect to environmental compliance matters.

Assists in strategic planning to rectify compliance issues should they occur.

Environmental

Compliance and

Performance

Manger

Co-ordinates and schedules audits of the CWMP.

Provides notification to regulatory authorities and key Australia Pacific LNG stakeholders

of incidents that may have caused or have the potential to cause environmental harm.

Ensures environmental non-compliances are reported in accordance with relevant

Australia Pacific LNG procedures and the Peat EA.

Project Manager -

Water Solutions

Oversees development of the project-specific CSG water management strategy in

consultation with regulatory authorities, key stakeholders and project personnel.

Provides technical assistance to the reviewing, reporting, auditing, monitoring and

training requirements of this CWMP.

Oversees and approves updates of the CWMP.

Oversees continuous improvement of CSG water management to optimise beneficial use.

Ensures adaptive management techniques are incorporated into water management

practice.

Facilitates technical advice and assistance for development and advancement of the

CWMP to stay abreast of relevant legislation.

Project Manager –

CSG Projects

Provision of engineering and construction management to ensure delivery of CSG water

management infrastructure.

Benchmarking and continual improvement of CSG water management infrastructure to

meet strategy and associated objectives outlined in CWMP.

Identifies hazards and risk associated with the operation and maintenance of CSG water

management infrastructure and develops, implements and monitors mitigation measures

accordingly.

Documents

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