Application to amend Environmental Authority, … Likely impacts and proposed management practices...

Application to amend Environmental

Authority, EPPG00694213

Supporting Information

Rev Date Details By Check App

1 9 March 2018 Submission version CS PD RC

Contents 1. INTRODUCTION .............................................................................................................................. 7

1.1 Background ............................................................................................................................. 7

1.2 Assessment Level decision ..................................................................................................... 8

1.3 Associated document references .......................................................................................... 8

2. APPLICATION REQUIREMENTS ....................................................................................................... 9

3. NEED FOR AMENDMENT .............................................................................................................. 16

3.1 Scope ..................................................................................................................................... 16

3.2 Proposed activities ............................................................................................................... 16

3.3 Risk context .......................................................................................................................... 17

3.4 Proposed conditions for additional activities ..................................................................... 18

4. IMPACT ASSESSMENT CRITERIA ................................................................................................... 22

4.1 Introduction .......................................................................................................................... 22

4.2 Assessment Approach .......................................................................................................... 22

5. AIR ................................................................................................................................................. 26

5.1 Existing environment ........................................................................................................... 26

5.2 Description of environmental values .................................................................................. 28

5.3 Emissions and releases ......................................................................................................... 28

5.4 Likely impacts and proposed management practices ......................................................... 28

5.4.1 Dust generation ............................................................................................................ 28

5.4.2 Exhaust emissions ........................................................................................................ 29

5.4.3 Fuel combustion (flaring) ............................................................................................. 29

5.4.4 Fugitive emissions ........................................................................................................ 29

5.4.5 Flare location and constraints planning ...................................................................... 29

5.5 Risk assessment .................................................................................................................... 31

6. LAND ............................................................................................................................................. 32


6.1.1 General ......................................................................................................................... 32

6.1.2 Geology ......................................................................................................................... 32

6.1.2.1 Faulting ......................................................................................................................... 34

6.1.3 Soils and land units ....................................................................................................... 37

6.1.4 Climate .......................................................................................................................... 38

6.1.5 Land Use ....................................................................................................................... 38




6.4.1 Chemical and flowback fluid storage ........................................................................... 39

6.4.2 Livestock interactions with stimulation fluid .............................................................. 40

6.4.3 Induced seismicity and subsidence .............................................................................. 40

6.5 Risk assessment .................................................................................................................... 41

7. NATURAL ENVIRONMENT ............................................................................................................ 42





7.4.1 Fire management ......................................................................................................... 44

7.4.2 Translocation of pests .................................................................................................. 44

7.4.3 Appropriate chemical storage...................................................................................... 45

7.4.4 Vehicle strike ................................................................................................................ 45

7.5 Risk assessment .................................................................................................................... 46

8. NOISE ............................................................................................................................................ 47





8.5 Risk assessment .................................................................................................................... 49

9. COMMUNITY ................................................................................................................................ 51





9.5 Risk assessment .................................................................................................................... 52

10. HERITAGE .................................................................................................................................. 54





10.5 Risk assessment .................................................................................................................... 55

11. WASTE ....................................................................................................................................... 56




11.4 Risk assessment .................................................................................................................... 59

12. WATER ...................................................................................................................................... 61


12.1.1 Surface water.................................................................................................................... 61

12.1.2 Groundwater .................................................................................................................... 61

12.1.3 Groundwater usage .......................................................................................................... 65

12.1.4 Groundwater dependent ecosystems ............................................................................. 67




12.4.1 Appropriate chemical storage...................................................................................... 68

12.4.2 Containment of stimulation fluid and flowback ......................................................... 68

12.4.3 Fracture migration ........................................................................................................ 69

12.4.4 Well construction and integrity ................................................................................... 69

12.5 Risk assessment .................................................................................................................... 69

13. STIMULATION ACTIVITIES ........................................................................................................ 71





13.4.1 Well construction and integrity ................................................................................... 77

13.4.2 Fracture migration ........................................................................................................ 77

13.4.3 Remnant fluid in formation ......................................................................................... 78

13.5 Risk assessment .................................................................................................................... 79

14. REHABILITATION ....................................................................................................................... 84

14.1 Decommissioning infrastructure ......................................................................................... 84

14.2 Transitional rehabilitation ................................................................................................... 84

14.3 Final rehabilitation ............................................................................................................... 84

14.4 Pre-fabricated tanks ............................................................................................................. 84

14.5 Road and access tracks ......................................................................................................... 85

14.6 Water crossings .................................................................................................................... 85

14.7 Flare pits ............................................................................................................................... 85

14.8 Dust emissions during rehabilitation ................................................................................... 86

14.9 Noise emissions during rehabilitation ................................................................................. 86

14.10 Light nuisance during rehabilitation ................................................................................ 86

14.11 Visual amenity of rehabilitated areas ............................................................................. 87

14.12 Rehabilitation success ...................................................................................................... 87

14.13 Rehabilitation monitoring and reporting ........................................................................ 88

15. REFERENCES .............................................................................................................................. 89

Table 2-1 Key Statutory Requirements ................................................................................................... 9

Table 3-1 Proposed conditions for EA amendment .............................................................................. 19

Table 4-1 Likelihood and scores for impact occurring .......................................................................... 23

Table 4-2 Consequence and scores of the impact occurring ................................................................ 24

Table 4-3 Risk scores ............................................................................................................................. 25

Table 5-1 Air - Likely impacts and key management practices ............................................................. 30

Table 6-1 Real property descriptions for PL 511 ................................................................................... 32

Table 6-2 Land Units and Dominant Soil Types .................................................................................... 37

Table 6-3 Land - Likely Impacts and Key Management Practices ......................................................... 40

Table 7-1 Terrestrial habitat types located in PL 511 ........................................................................... 42

Table 7-2 Threatened Species Confirmed or Possible to Occur within PL 511 ..................................... 43

Table 7-3 Natural environment - likely impacts and key management practices ................................ 46

Table 8-1 Noise- Likely impacts and key management practices ......................................................... 49

Table 8-2 Best practice noise emission limits for oil and gas ............................................................... 50

Table 9-1 Community - Likely impacts and key management practices ............................................... 52

Table 10-1 Heritage - Likely impacts and key management practices.................................................. 55

Table 11-1 Waste likely to be generated and key management measures .......................................... 57

Table 12-1 Major aquifers underlying PL 511 ....................................................................................... 62

Table 12-2 Hydraulic properties of underlying aquitards ..................................................................... 63

Table 12-3 Water bores located within PL 511 ..................................................................................... 65

Table 12-4 Water - Likely impacts and key management practices ..................................................... 69

Table 13-1 Stimulation Activities - Likely impacts and key management practices ............................. 79

Figure 1 Armour Energy Ltd ACN 141 198 414 (Armour), is authorised to conduct petroleum

activities within petroleum leases PL 14, PL 53, PL 70 and PL 511 (Kincora), located in the Surat Basin

................................................................................................................................................................ 7

Figure 2 Location of sensitive receptors and petroleum infrastructure for PL 511.............................. 27

Figure 3 Local and regional stratigraphy underlying PL 511 ................................................................. 36

Figure 4 Regional hydrostratigraphy ..................................................................................................... 64

Figure 5 Water bore proximity to proposed petroleum wells in PL 511 .............................................. 66

1. INTRODUCTION

1.1 Background

Armour Energy (Surat Basin) Pty Ltd ACN 607504905, a wholly-owned subsidiary of Armour Energy

Ltd ACN 141 198 414 (Armour), is authorised to conduct petroleum activities within petroleum

leases PL 14, PL 53, PL 70 and PL 511 (Kincora), located in the Surat Basin (Figure 1), in accordance

with corresponding Environmental Authority, number EPPG00694213 (EA).

Armour acquired the Kincora project in September 2015 and is currently in the process of

recommissioning the gas and LPG plant, and intends to undertake a drilling and well stimulation

campaign in PL 511 sometime in 2018.

Although there is no express prohibition of hydraulic stimulation activities in the EA, the use of

hydraulic stimulation fluid may nonetheless constitute a release of contaminants to land or waters,

which would be in contravention of current EA conditions.

Accordingly, Armour seeks to amend the EA to the extent that hydraulic stimulation activities would

be expressly authorised in PL 511.

Figure 1 Armour Energy Ltd ACN 141 198 414 (Armour), is authorised to conduct petroleum

activities within petroleum leases PL 14, PL 53, PL 70 and PL 511 (Kincora), located in the Surat Basin

1.2 Assessment Level decision

Section 223 of the Environmental Protection Act 1994 (EP Act) defines a “major amendment”, for an

EA, as an amendment that is not a “minor amendment.”

A “minor amendment” is an amendment that involves either a condition conversion or an

amendment that meets the minor amendment threshold.

The proposed amendment does not involve a condition conversion and does not satisfy the minor

amendment threshold and is therefore a major amendment.

1.3 Associated document references

▪ Armour Energy (Surat Basin) Pty Ltd “Surat Operations Environmental Management Plan”

▪ Armour Energy (Surat Basin) Pty Ltd “Site Emergency Response Plan - Surat Basin”

▪ Armour Energy “Well Integrity Management Plan”

▪ Armour Hydraulic Stimulation Risk Assessment.

2. APPLICATION REQUIREMENTS Section 226 of the EP Act sets out the requirements for a properly made application to amend an EA.

Armour can advise that this amendment application:

(a) has been made to the Department of Environment and Science (DES) (“the administering

authority”);

(b) has been provided in the approved form;

(c) is accompanied by the fee, prescribed under the regulation, of $316.60;

(d) includes a clear description of the proposed amendment to undertake hydraulic stimulation

activities within PL 511;

(e) includes a full description of the land that will be affected by the proposed amendment has been

provided;

(f) is not subject to any development permits in effect under the Sustainable Planning Act 2009;

(g) does not comply with the “eligibility criteria”;

(h) does not include a declaration of compliance with the “eligibility criteria”;

(i) does not seek to change a standard condition;

(j) does not relate to a new resource tenure;

(k) includes a description of the environmental values, likely emissions, risks and impacts,

management practices, relevant waste management and rehabilitation actions;

(l) does not relate to land that is subject to any SMP or EPO; and

(m) does not involve coals seam gas (CSG) activities and there are no prescribed documents required

for this amendment application.

In addition to the above mandatory application requirements, a comprehensive register of all key

statutory requirements has been developed and included in Table 2-1 below.

Table 2-1 Key Statutory Requirements

LEGISLATION SECTION REQUIREMENT REFERENCE

Requirements for properly made application

EP Act 226(1)(a) Application made to

administering authority

See attached application form

EP Act 226(1)(b) Application made in the

approved form

See attached application form

EP Act 226(1)(c) Application accompanied by the

prescribed fee

Fee accompanying application

EP Act 226(1)(d) Description of proposed

amendment

Sections 3.2 and 3.4

EP Act 226(1)(e) Description of land affected by

the proposed amendment

Section 6.1


EP Act 226(1)(f) N/A no Development Approval

required under Sustainable

Planning Act 2009

N/A

EP Act 226(1)(g) N/A - The activity does not

comply with the eligibility criteria

N/A

EP Act 226(1)(h) N/A – the activity does not

comply with any eligibility criteria

N/A

EP Act 226(1)(i) There is no amendment to a

standard condition

N/A

EP Act 226(1)(j) N/A –does not involve standard

conditions

N/A

EP Act 226(1)(k)(i) Description of EVs likely to be

affected by proposed

amendment

Sections 5.2, 6.2, 7.2, 8.2, 9.2, 10.2, 11.1,

12.2 and 13.2

EP Act 226(1)(k)(ii) Details of any emissions likely to

be generated by proposed

amendment

Sections 5.3, 6.3, 7.3, 8.3, 9.3, 10.3, 11.2,

12.3 and 13.3

EP Act 226(1)(k)(iii) Description of risk and likely

magnitude of impacts on EVs

Sections 5.5, 6.5, 7.5, 8.5, 9.5, 10.5, 11.4,

12.5 and 13.5

EP Act 226(1)(k)(iv) Proposed management practices Sections 5.4, 6.4, 7.4, 8.4, 9.4, 10.4, 11.3,

12.4 and 13.4

Tables 5-1, 6-3, 7-3, 8-2, 9-1, 10-1, 11-1,

12-1 and 13-1

EP Act 226(1)(k)(v) Details of rehabilitation Section 14

EP Act 226(1)(l) Proposed waste management

measures

Section 11.3

EP Act 226(1)(m) No relevant SMPs or EPOs N/A

EP Act 226(1)(n) N/A not a CSG project N/A

EP Act 226(2)(a) EIS process not relevant to

proposed amendment

N/A

EP Act 226(2)(b) N/A - EIS process not relevant to

proposed amendment

N/A

EP Act 226(3) N/A - EIS process not relevant to

proposed amendment

N/A

EP Act Sch 4 Consideration of ‘Standard

Criteria’

Sections 5.4, 6.4, 7.4, 8.4, 9.4, 10.4,

11.3, 12.4 and 13.4

EP Act Sch 4 the precautionary principle; Tables 5-1, 6-3, 7-3, 8-2, 9-1, 10-1, 11-

1, 12-1 and 13-1

EP Reg 51(1)(a) Consideration of environmental

objective and performance

outcomes (Schedule 5, Part 3,

Tables 1 and 2)

Sections 5.4, 6.4, 7.4, 8.4, 9.4, 10.4,

11.3, 12.4 and 13.4

Tables 5-1, 6-3, 7-3, 8-2, 9-1, 10-1, 11-

1, 12-1 and 13-1


EP Reg 51(1)(b) Consideration of declared EVs Sections 5.2, 8.2, 9.2, 11.1 and 12.2

EP Reg 51(1)(ba) Consideration of Strategic

Environmental Area’s

Section 6.1

EP Reg 51(1)(c) Consideration of EPP’s Sections 5.2, 8.2, 9.2, 11.1 and 12.2

EP Reg 51(1)(i) Consideration of management

hierarchy of EPPs

Sections 5.2, 8.2, 9.2, 11.1 and 12.2

EP Reg 51(1)(ii) Consideration of EVs in EPPs Sections 5.2, 8.2, 9.2, 11.1 and 12.2

EP Reg 51(1)(iii) Consideration of quality

objectives in EPPs

Sections 5.2, 8.2, 9.2, 11.1 and 12.2

EP Reg 51(1)(iv) Consideration of management

intent of EPPs

Sections 5.2, 8.2, 9.2, 11.1 and 12.2

EP Reg 51(1)(d) Consideration of bilateral

agreement not required (not EIS

process)

N/A

EP Reg 51(1A) N/A – not a coordinated project N/A

EP Reg Schedule 5 Environmental Objectives and

Performance Outcomes:

Sections 5.4, 6.4, 7.4, 8.4, 9.4, 10.4,

11.3, 12.4 and 13.4

Tables 5-1, 6-3, 7-3, 8-2, 9-1, 10-1, 11-

1, 12-1 and 13-1

EP Reg Schedule 5 Operational Assessment - Air Section 5.4; Table 5-1

EP Reg Schedule 5 Operational Assessment - Water Section 12.4; Table 12-1

EP Reg Schedule 5 Operational Assessment -

Wetlands

Section 12

EP Reg Schedule 5 Operational Assessment -

Groundwater

Section 12.4; Table 12-1

EP Reg Schedule 5 Operational Assessment – Noise Section 8.4; Table 8-2

EP Reg Schedule 5 Operational Assessment - Waste Section 11.3; Table 11-1

EP Reg Schedule 5 Operational Assessment - Land Sections 6 and 7

EP Reg Schedule 5 Land Use Assessment – Site

Suitability

Sections 5.4, 6.4, 7.4, 8.4, 9.4, 10.4,

11.3, 12.4 and 13.4

Tables 5-1, 6-3, 7-3, 8-2, 9-1, 10-1, 11-

1, 12-1 and 13-1

EP Reg Schedule 5 Land Use Assessment – Location

on site

Sections 5.4, 6.4, 7.4, 8.4, 9.4, 10.4,

11.3, 12.4 and 13.4

Tables 5-1, 6-3, 7-3, 8-2, 9-1, 10-1, 11-

1, 12-1 and 13-1

EP Reg Schedule 5 Land Use Assessment – Critical

design requirements

Sections 5.4, 6.4, 7.4, 8.4, 9.4, 10.4,

11.3, 12.4 and 13.4

Tables 5-1, 6-3, 7-3, 8-2, 9-1, 10-1, 11-

1, 12-1 and 13-1

EP Reg 81A Environmental Values for

wetlands

Section 12


Air EPP 7 Prescribed ‘environmental

values’ for air

Section 5.2

Noise EPP 7 Prescribed ‘environmental

values’ for noise

Section 8.4

Water EPP 6(1) Prescribed ‘environmental

values’ for water

Section 12.4

Waste Reduction and

Recycling Act 2011

9 Management hierarchy for waste Section 11

DES document,

Guideline - Application

requirements for

petroleum activities”

3.9 a process description of the

stimulation activity to be applied,

including equipment and a

comparison to best international

practice

Sections 3.1, 3.2, 13, Table 13-1,

Armour Hydraulic Stimulation Risk

Assessment.

DES document,


requirements for


3.9 details of where, when and how

often stimulation is to be

undertaken on the tenures

covered by this environmental

authority

Sections 3.1 and 3.2

DES document,


requirements for


3.9 a geological model of the field to

be stimulated including

geological names, descriptions

and depths of the target gas

producing formation(s)

Section 6.1.2, Figure 6-2

DES document,


requirements for


3.9 naturally occurring geological

faults

Section 6.1.2.1

DES document,


requirements for


3.9 seismic history of the region (e.g.

earth tremors, earthquakes)

Section 6.1.2.1

DES document,


requirements for


3.9 proximity of overlying and

underlying aquifers

Section 12.1.2, Tables 12-1, Figure 12-1

DES document,


requirements for


3.9 description of the depths that

aquifers with environmental

values occur, both above and

below the target gas producing

formation

Section 12.1.2, Tables 12-1, Figure 12-1

DES document,


requirements for


3.9 identification and proximity of

landholders’ active groundwater

bores in the area where

stimulation activities are to be

carried out

Section 12.1.3, Figures 12-4 and 12-5

DES document,


3.9 the environmental values of

groundwater in the area

Section 12.2


requirements for


DES document,


requirements for


3.9 an assessment of the appropriate

limits of reporting for all water

quality indicators relevant to

stimulation monitoring in order

to accurately assess the risks to

environmental values of

groundwater


Assessment.

DES document,


requirements for


3.9 description of overlying and

underlying formations in respect

of porosity, permeability,

hydraulic conductivity, faulting

and fracture propensity

Sections 6.1.2 and 12.1.2, Figures 6-2,

12-1, 12-2 and 12-3, and Armour

Hydraulic Stimulation Risk Assessment.

DES document,


requirements for


3.9 consideration of barriers or

known direct connections

between the target gas

producing formation and the

overlying and underlying aquifers

Sections 6.1.2 and 12.1.2, Figures 6-2,

12-1, 12-2 and 12-3

DES document,


requirements for


3.9 a description of the well

mechanical integrity testing

program

Section 13, Armour Hydraulic

Stimulation Risk Assessment, Well

Integrity Management Plan

DES document,


requirements for


3.9 process control and assessment

techniques to be applied for

determining extent of stimulation

activities (e.g. microseismic

measurements, modelling etc)




DES document,


requirements for


3.9 practices and procedures to

ensure that the stimulation

activities are designed to be

contained within the target gas

producing formation




DES document,


requirements for


3.9 groundwater transmissivity, flow

rate, hydraulic conductivity and

direction(s) of flow

Section 12.1.2, Figures 12-1, 12-2 and

12-3

DES document,


requirements for


3.9 a description of the chemical

compounds used in stimulation

activities (including estimated

total mass, estimated

composition, chemical abstract

service numbers and properties),

their mixtures and the resultant

compounds that are formed after

stimulation


Stimulation Risk Assessment

DES document,


3.9 a mass balance estimating the

concentrations and absolute

masses of chemical compounds

that will be reacted, returned to


Assessment


requirements for


the surface or left in the target

gas producing formation

subsequent to stimulation

DES document,


requirements for


3.9 an environmental hazard

assessment of the chemicals used

including their mixtures and the

resultant chemicals that are

formed after stimulation

including:

- toxicological and

ecotoxicological information of

chemical compounds used

- information on the persistence

and bioaccumulation potential

of the chemical compounds

used

- identification of the chemicals

of potential concern in

stimulation fluids derived from

the risk assessment



DES document,


requirements for



assessment of use, formation of,

and detection of polycyclic

aromatic hydrocarbons in

stimulation activities


Assessment

DES document,


requirements for


3.9 confirmation and identification of

whether radioactive tracer beads

are used and if so, an

environmental hazard

assessment of their use in




DES document,


requirements for



assessment of leaving chemical

compounds in stimulation fluids

in the target gas producing

formation for extended periods

subsequent to stimulation


Assessment

DES document,


requirements for


3.9 human health exposure

pathways to operators and the

regional population


Assessment

DES document,


requirements for


3.9 risk characterisation of

environmental impacts based on

the environmental hazard

assessment



DES document,


requirements for


3.9 potential impacts to landholder

bores as a result of stimulation

activities




DES document,


requirements for


3.9 an assessment of cumulative

underground impacts, spatially

and temporally, of the

stimulation activities to be

carried out on the tenures

covered by the environmental

authority



DES document,


requirements for


3.9 potential environmental or

health impacts which may result

from stimulation activities

including but not limited to water

quality, air quality (including

suppression of dust and other

airborne contaminants), noise

and vibration.

throughout

DES document,


requirements for


3.9 evidence that fluids used in

stimulation will not include

restricted stimulation fluids



3. NEED FOR AMENDMENT

3.1 Scope The Kincora project is a successful natural gas and liquid hydrocarbon-rich producing asset, with

production from the subject PL 511 commencing in the late 1990’s.

In 2012, the Kincora project was mothballed and put under care and maintenance in 2012 by then

operator, Origin Energy, and remained in that state until Armour’s acquisition of the asset in

September 2015.

Armour is currently in the process of recommissioning the gas and LPG plant as well as undertaking a

drilling and well stimulation campaign in PL 511.

The existing EA already provides Armour with broad authority to undertake a range of petroleum

activities, specifically:

▪ ERA 15-Fuel burning >500kg hr;

▪ ERA 60-(1a) Waste disposal <50000t yr (1)(a);

▪ ERA 60-(2a) Waste disposal >50t but <2000t yr (1)(b);

▪ ERA 9-(c) Hydrocarbon gas refining - coal seam gas;

▪ Petroleum - 3 impact environmentally sensitive areas;

▪ Petroleum - 6 site with high/significant hazard dam; and

▪ Petroleum - 8 other than 1 to 7 with a prescribed ERA.

However, as the EA does not explicitly authorise hydraulic stimulation activities, Armour is seeking a

major amendment of its EA to authorise the hydraulic stimulation of five wells targeting the Rewan

Formation (and potentially deeper formations) underlying PL 511 in order to facilitate the proposed

well drilling and stimulation campaign.

There are no additional Environmentally Relevant Activities or additional “relevant acts” proposed

under this amendment.

3.2 Proposed activities Hydraulic stimulation will be undertaken in the Rewan and deeper formations at depths of more

than 1800 metres.

Each well will be perforated at depth (i.e. within the section of casing located in the reservoir) so

that the stimulation fluid can be pumped into that target.

Approximately 2-3 megalitres of pre-mixed stimulation fluid (comprising of approximately 96%

water, 3.5% or more of ceramic proppant and 0.5% or less of trace additives) will then be pumped

from the surface down into the well casing under high pressure (around 6,000-7,000psi) to create

controlled fractures in the target formation.

Downhole pressure and fluid viscosity will be closely monitored throughout the hydraulic stimulation

process so as to be able to respond to unexpected pressure changes that could adversely affect well

integrity.

The stimulation fluid will then be pumped back to the surface (flowback) with an expected 60% of

the stimulation fluid returning to the surface. Note that PL 511 is a “wet-gas” field (methane, plus

various liquid hydrocarbon components) and so there is a much lower volume of flowback expected

to return to the surface when compared to a conventional oil or coal seam gas well.

Well stabilisation dosing may be undertaken to preserve the hydraulic stimulation job between well

completion and well production.

Flowback fluid will be collected and temporarily stored in modular, pre-fabricated tanks supplied by

service and equipment supplier, Kinetic. Flowback fluid will be reused wherever possible and later

disposed of offsite. A hydraulic fracturing operation takes up to a week for each well. Prior to the

hydraulic fracturing operation, the well pad and ponds for water fluid management are constructed.

After the hydraulic fracturing operation is completed the flow back of fluids will be managed and the

site will be rehabilitated leaving only the operating well-head facility.

Produced water will be collected and disposed of via evaporation ponds. Hydrocarbon liquids will be

collected and pumped to storage tanks.

3.3 Risk context Armour has designed its operations specifically to minimise potential environmental risks as far as

practical. Where relevant, Armour has used existing material published by DES, such as the risk

assessment developed to support the Standard Conditions and Eligibility Criteria for Petroleum

Exploration as well as the risk assessment developed for the Streamlined Model Conditions for

Petroleum Production.

Armour has analysed the scope of the activities subject to this amendment and determined that the

risk profile is aligned with the Eligibility Criteria and Standard Conditions for Exploration due to:

▪ While this is a production project not exploration, it only relating to 5 wells, which is well within

the 1% land disturbance threshold in PEEC3

▪ Does not propose any of the activities listed in PEEC4 including:

o Injection of wastes (all wastes will be removed from site to a licensed facility)

o Regulated dams (fluids will be stored in prefabricated tanks)

o Any of the listed prescribed ERAs

▪ Not involving stimulation of formations within the 2km horizontal and 200m vertical thresholds

of standard condition PESCC35

▪ Does not propose the use of underground water rights to source water to be used in the


In relation to the last point, it is critical to note that the risk profile associated with stimulation for

conventional oil and gas activities such as those proposed to be carried out by Armour, and coal

seam gas are vastly different. This is explored in more detail in the stimulation section, however is

centred around much greater separation of the target formation and formations used for water

resources (>1km vs. no separation at all in some CSG areas); the fact that there is very little water

contained within the target formations, meaning there is much less flowback to be managed and

lower well densities (and exclusive use of directional drilling). As such, many of the standard

requirements of DES’ guiding material which is targeted at CSG activities is not relevant to Armour’s

proposed activities. Where this is the case, a rationale has been provided in each relevant section.

3.4 Proposed conditions for additional activities Armour proposes the following modified standard conditions for this amendment (Table 3-1).

Although the proposed activities do not strictly meet the “eligibility criteria” for a standard approval

(because PL 511 is a production tenure), Armour understands that standard conditions can be used…

where it is necessary and desirable for a site specific environmental authority - and seeks the

inclusion of certain standard conditions.

It is noted that Armour has discussed with DES a general desire to contemporise all conditions in its

existing EAs, however this will be a separate process and is currently outside of the scope of this

specific amendment.

Table 3-1 Proposed conditions for EA amendment

Proposed conditions Rationale

New condition 1: Stimulation activities are authorised at a maximum of five (5) wells.

In order to expedite the approval process, impact assessments have only been conducted for the five nominated wells and target formation group.

New condition 2: Water for stimulation activities must not be obtained through use of the holder’s underground water rights under the Petroleum and Gas (Production and Safety) Act 2004

Armour proposes that water for well stimulation activities shall be sourced from Maranoa Shire Council so that the impact on groundwater water resources and users is minimised to the greatest extent practicable.

Contingency and emergency response for stimulation activities PESCC 7. Stimulation activities involving significant disturbance to land or which have the potential to cause environmental harm can only commence after the development of written contingency procedures which address the risks of non-compliance with Schedule B standard conditions.

The current EA already authorises and extensive range of activities, therefore additional conditions relating to contingency and emergency response should be confined to the activities proposed by this amendment application.

PESCC 8. The contingency procedures must include, but not necessarily be limited to: (a) environmental nuisance and complaint

management procedures including: i. a description of the petroleum activities

that might result in non-compliance with Schedule B

standard conditions and what mitigation measures are required to be implemented; and

ii. the action that will be undertaken when a member of the public makes a valid complaint

(b) management procedures including details of what actions will be taken to protect environmental

values and minimise potential environmental harm from petroleum activities as a result of floods, severe storms and fires (c) environmental emergency management

procedures including details of the response and mitigation measures that will be actioned to reduce negative impacts to environmental values in the event of a non-compliance with Schedule B standard conditions

The current EA already authorises and extensive range of activities, therefore additional conditions relating to contingency and emergency response should be confined to the activities proposed by this amendment application.

Chemical Storage PESCC 16.

Chemical and fuel storage is already contemplated in existing EA conditions.


Chemicals and fuels for stimulation activities must be stored in, or serviced by, an effective containment system that meets Australian Standards, where such a standard is relevant.

Therefore, rather than re-assessing the entire project, additional chemical storage conditions should be confined to the proposed stimulation activities.

PESCC 25. Stimulation waste products, including waste fluids but excluding waste gas and produced water, must be transported off-site for lawful re-use, remediation, recycling or disposal unless the waste is specifically authorised by standard conditions (PESCC 26), (PESCC 27), (PESCC 28), (PESCC 29), (PESCC 30), (PESCC 31), (PESCC 32) or (PESCC 34) to be disposed of or used on-site.

Waste disposal is already contemplated in existing EA conditions. Therefore, rather than re-assessing the entire project, additional waste disposal conditions should be confined to the proposed stimulation activities. Note that evaporation ponds are authorised for produced water disposal.

PESCC 29. Produced water and stimulation flow-back water may be reused in: (a) drilling and well hole activities; or (b) stimulation activities where its use will not result

in negative effects on waters beyond the stimulation impact zone.

Re-use of produced water is consistent with the Waste Hierarchy

Stimulation Activities PESCC 35. The petroleum activities must not involve well stimulation activities at a well located within 2 kilometres laterally of a landholder’s active groundwater bore and sourced from a formation within 200 metres vertically of the stimulation impact zone.

There will be a total of 19 petroleum wells located within PL 511. The proposed hydraulic stimulation campaign will be undertaken in five wells or less. Armour is aware that this is a considerably smaller surface footprint and underground impact than a coal seam gas exploration project that could otherwise obtain a standard-conditioned approval. There will be no large-scale dewatering of aquifers to extract gas or hydrocarbon liquids after well stimulation activities are complete. Risks to groundwater quality will be negligible as there is significant vertical separation and geological barriers between landholder groundwater bore sources and the target Rewan Formation that would prevent impacts to landholder water quality. The closest water bore is 1233 metres laterally and at a depth of 152.4 metres, which is at least 1600 metres of vertical separation from the target formation. Risks to noise and air values as the closest sensitive receptor (dwelling) is 1530 metres from

PESCC 36. Prior to undertaking well stimulation activities, written stimulation management procedures must be developed. Explanatory note: The stimulation management procedures may incorporate other documents by reference.

PESCC 37. Stimulation activities must not result in: (a) negative impacts to groundwater quality beyond

the stimulation impact zone; or (b) negative impacts to water quality in landholder’s

active groundwater bore(s) which tap into the target formation; or

(c) interconnectivity between the target formation and another aquifer.


the nearest well. The next closest dwelling is 2467 metres away.

PESCD 1. All monitoring for stimulation activities must be undertaken by a suitably qualified person.

Monitoring is already contemplated in current EA conditions for existing activities. Therefore, rather than re-assessing the entire project, additional monitoring conditions should be confined to the proposed stimulation activities under the sub-heading “Stimulation Activities” in the EA.

PESCD 3. All laboratory analyses and tests must be undertaken by a laboratory that has NATA accreditation for such analyses and tests, except as otherwise authorised in writing by the administering authority.

Monitoring is already contemplated in current EA conditions for existing activities. Therefore, rather than re-assessing the entire project, additional monitoring conditions should be confined under the sub-heading “Stimulation Activities” in the EA.

PESCD 4. Notwithstanding standard condition (PESCD 3), where there are no NATA accredited laboratories available to test for a specific analyte or substance, then duplicate samples must be sent to separate laboratories for independent testing or evaluation.


PESCD 8. The methods of groundwater sampling must comply with the Australian Government’s Groundwater Sampling and Analysis – A Field Guide (2009:27 GeoCat #6890.1).


4. IMPACT ASSESSMENT CRITERIA 4.1 Introduction

Sections 5 to 13 provide a description of existing environment and the environmental values that

have the potential to be affected as a result of proposed stimulation activities within PL 511. For

each environmental value (land, water, air, noise, social, heritage and waste), likely impacts and

corresponding environmental management practices are identified. Environmental management,

control strategies and commitments have been proposed to minimise the impact of the proposed

activities on each environmental value.

Armour has undertaken this assessment considering the application requirements outlined in the

DES document, “Guideline - Environmental Protection Act 1994 (EP Act) - Application requirements

for petroleum activities”, and the requirements of the EP Act and other relevant legislation.

To demonstrate that Armour has considered all potential impacts of the proposed activities, the

following assessment approach has been utilised in this instance.

4.2 Assessment Approach

Technical assessments undertaken by appropriately qualified and experienced persons for each

relevant environmental value have been used to guide the process of assessment of likely impacts

for the proposed activities, selection of management practices and consideration of the residual risk.

Description of environmental values

Environmental values are defined by the EP Act to include:

▪ a quality of physical characteristic of the environment that is conducive to ecological health or

public amenity or safety (environmental value); or

▪ another quality of the environment identified and declared to be an environmental value under

an environmental protection policy or regulation (prescribed environmental value).

These values have been described for Pl 511 and as appropriate additional areas may be included to

inform an assessment of indirect impacts or cumulative impacts.

Emissions and releases

Emissions and releases, as they relate to each environmental value are identified with reference to

the relevant production activities. Details of emissions and releases have been documented where

available to consider both planned and unplanned emissions and releases.

Likely impacts and environmental management practices

Likely impacts as a result of proposed activities in PL 511 have been identified for each

environmental value. The type and extent of likely impacts, the application of the mitigation

hierarchy and Armour’s existing management plans and policies has been considered for developing

appropriate environmental management practices.

Armour shall endeavour to implement appropriate management practices to manage likely impacts

of the proposed activities.

Risk Assessment

The residual risk of harm to environmental values has been assessed by suitably qualified and

experienced specialists. The risk assessment has considered the magnitude, severity and duration of

likely impacts following implementation of proposed management measures

Armour has quantified the environmental risks of the amendment by applying the former

Department of Environment and Heritage Protection risk assessment tool for standard conditions

that was developed in conjunction with the petroleum industry.

Risk was determined by considering the likelihood that a particular risk event occurs, and its

resultant consequence. Likelihood is based on the probability that an event will occur and the

amount of time (exposure) that the event could occur in.

The consequence rating (1 – 5) corresponds to the maximum reasonable impact. Probability is

determined (P1-P5) from the Likelihood Rating Table, that the Consequence could be realised, i.e.

the probability of the event occurring.

The risk score is based on the likelihood and consequence rating and categorised as rare, unlikely,

possible, likely, or almost certain.

Table 4-1 Likelihood and scores for impact occurring

Score Descriptor Description

1 Rare May occur only in exceptional circumstances but no history of such an event occurring

2 Unlikely Unlikely to occur, but a history of the event in the industry or activity

3 Possible Might occur at some time. Clear evidence of such events / general view they could occur

4 Likely Will probably occur > 50% change of occurring

5 Almost Certain

Is expected to occur in most circumstances

Table 4-2 Consequence and scores of the impact occurring

Score Descriptor Description

1

Minor Minor environmental damage (e.g.) ~Limited damage to minimal area of low significance ~Little or no environmental harm

2

Moderate

Moderate environmental damage (e.g.) ~ Environmental harm which is localised and easily rehabilitated ~ Spill of a small volume of contaminants which is contained on site ~ Short term damage to a small area of little environmental significance ~ Environmental nuisance complaint from resident

3

Serious

Serious environmental damage (e.g.) ~ Spill released from site which does not impact on ecosystem function ~ Short term impact on protected species ~ Several environmental nuisance complaints from the community

4

Major

Major environmental damage (e.g.) ~ Short-term harm that is widespread or of a high impact. ~ Harm caused to an area of high conservation value or special significance ~ Harm affecting the health of a group of people ~ Death of protected species ~ Spill with short to medium term impact on ecosystem function ~ Broad public concern at regional level due to environmental nuisance

5

Catastrophic

Catastrophic environmental damage (e.g.) ~ Long-term harm that is widespread or of a high impact ~ Irreparable damage to an environmental value ~ Environmental harm which causes a fatality ~ Destruction of protected ecosystems ~ Spill with long term impact on ecosystem function ~ Action that contributes to the extinction of a species

Table 4-3 Risk scores

Likelihood

Consequences Rare (1)

Unlikely (2)

Possible (3)

Likely (4)

Almost Certain (5)

Minor (1)

1 2 3 4 5

Moderate (2)

2 4 6 8 10

Serious (3)

3 6 9 12 15

Major (4)

4 8 12 16 20

Catastrophic (5)

5 10 15 20 25

5. AIR

5.1 Existing environment The Surat Basin region is characterised by a subtropical climate with a distinct dry season between

April and September and a wet season between October and March.

Air quality in the vicinity of PL 511 is impacted to varying extents by dust emissions from traffic on

unsealed roads, industrial activities, wind erosion and dust storms. In addition to dust, the

surrounding industrial uses emit other gaseous emissions, including oxides of nitrogen (NOx), carbon

monoxide (CO), sulphur dioxide (SO2) and VOCs.

Historical data also indicates the presence of fugitive gas emissions from natural gas seeps in and

around Surat and the broader Roma region as early as 1889 (well before the expansion of the

natural gas industry in the region) (APPEA, 2016).

There are two sensitive receptors in the form of temporary farm accommodation located 1530 and

2467 metres from the closest well proposed for stimulation.

Figure 5-1 provides the location of petroleum infrastructure and sensitive receptors within PL 511.

Figure 5-1 Location of sensitive receptors and petroleum infrastructure for PL 511

5.2 Description of environmental values Under the Environmental Protection (Air) Policy 2008 (Air EPP), the environmental values to be

enhanced or protected are—

▪ the qualities of the air environment that are conducive to protecting the health and biodiversity

of ecosystems; and

▪ the qualities of the air environment that are conducive to human health and wellbeing; and

▪ the qualities of the air environment that are conducive to protecting the aesthetics of the

environment, including the appearance of buildings, structures and other property; and

▪ the qualities of the air environment that are conducive to protecting agricultural use of the

environment.

5.3 Emissions and releases The potential impacts upon air environmental values that may be associated with hydraulic

stimulation activities include:

▪ Dust and vehicle exhaust emissions from service provider vehicles;

▪ Fuel combustion emissions from the operation of hydraulic stimulation spread at the well sites;

▪ Emissions from flared gas once stimulation activities have ceased; and

▪ Fugitive emissions from well heads and associated infrastructure.

The use of diesel-fired equipment during the proposed activities will also result in emissions of diesel

combustion products. However, these exhaust emissions will occur over a relatively wide area and it

is the fugitive dust emissions that would have the greatest potential for off-site impacts.

5.4 Likely impacts and proposed management practices The environmental management and mitigation measures proposed for air environmental values are

outlined below and summarised in Table 5.1.

5.4.1 Dust generation Varying amounts of dust may be generated during periods of high vehicle movements and may

potentially impact upon sensitive receptors in proximity to the sources.

Staff and contractors will be made aware through general site induction and training of the potential

to generate dust emissions and mitigation and management measures that should be implemented.

Armour shall manage dust emissions in accordance with the Air EPP management hierarchy, that is:

avoid, recycle, minimise and manage. Dust shall be minimised to the greatest extent practicable

through vigilante observation of meteorological conditions, road conditions, etc. in the first instance

to avoid dust generation. Armour’s current management practices for environmental nuisance (such

as dust) involve, among other things, preferentially locating nuisance sources away from near

sensitive receptors and utilising equipment that minimises the sources of environmental nuisance.

Armour will also address the management of air quality impacts, such as dust, through a complaints-

based process in accordance with EA conditions and regulatory requirements. Appropriate

corrective actions will then be taken, commensurate to the magnitude of the impact.

5.4.2 Exhaust emissions Exhaust emissions from stimulation equipment and onsite traffic are unlikely to make a significant

impact on local air quality. Nonetheless, appropriate vehicle, plant and equipment maintenance shall

be undertaken to ensure all machinery is in good working order and does not generate excessive air

emissions. Exhaust emissions shall be recorded and reported in accordance with the National

Greenhouse and Energy Reporting Act 2007 (Cth) and National Greenhouse and Energy Reporting

(Measurement) Determination 2008 (Cth).

5.4.3 Fuel combustion (flaring) Following the stimulation activities, waste gas that is produced from each well will be flared in

accordance with the specific requirements under the Petroleum and Gas (Production and Safety) Act

2004. Controlled flaring of waste gas will help to reduce any odorous characteristics that may be

present. Where necessary, flare emissions shall be recorded and reported in accordance with the

National Greenhouse and Energy Reporting Act 2007 (Cth) and National Greenhouse and Energy

Reporting (Measurement) Determination 2008 (Cth).

5.4.4 Fugitive emissions There is the potential for fugitive emissions to emanate from petroleum wells that have been poorly

constructed and completed. However, these emissions can be largely mitigated through adherence

to proper engineering standards and construction protocols. Armour’s petroleum wells are designed

and constructed in accordance with Armour’s Well Integrity Management Plan and accepted

industry standards.

5.4.5 Flare location and constraints planning Installation of flare infrastructure shall be undertaken in accordance with an appropriate constraints

analysis (including sensitive receptors). This would involve a review of GIS mapping layers relating to

the proposed infrastructure location(s).

Depending on the specific nature of any environmental or other constraints identified during the

desktop assessment, the proposed location may be revised and the new location selected to avoid

or minimise the impacts on the constraining environmental values where possible.

Once a preferred location is identified, site surveys would be undertaken to confirm the suitability of

the location. Other considerations may include:

▪ Discussions with landholders to identify on-ground constraints and to confirm preferred

location(s);

▪ Survey of infrastructure locations by engineering staff to confirm feasibility;

▪ where necessary, ecological ground-truthing undertaken to confirm the likelihood of habitat for

protected fauna, the occurrence of protected flora, regional ecosystems and ecological

communities, prescribed environmental matters, and validation of mapped watercourses.

Should site surveys locate constraints that were not otherwise identified through the desktop

environmental constraints analysis, flare location may be modified or revised, per the

aforementioned process.

Table 5-1 Air - Likely impacts and key management practices

Likely Impacts Key Management Practices

▪ Generation of dust – largely during periods

of high vehicle movements has the

potential to impact sensitive receptors in

proximity to the sources.

▪ Exhaust emissions - typically, exhaust

emissions from stimulation equipment and

onsite traffic are unlikely to make a

significant impact on local air quality.

▪ Fuel combustion emissions - emissions as a

result of fuel combustion by operational

equipment

▪ Fugitive emissions

▪ Armour shall manage dust emissions in

accordance with the Air EPP management

hierarchy, that is: avoid, recycle, minimise

and manage

▪ Staff and contractors will be made aware

through general site induction and training

of the potential to generate dust emissions

and mitigation and management measures

that should be implemented. Specific dust

management protocols outlined in the

Surat Operations Environmental

Management Plan shall be followed.

▪ Regular vehicle, plant and equipment

maintenance to ensure all machinery is in

good working order and does not generate

excessive air emissions. Plant and

equipment operated in their proper and

effective condition.

▪ Vehicles operated in a fuel-efficient manner

and not be left idling longer than required.

▪ Vehicles, plant and machinery must comply

with site-specific speed limits to minimise

dust generation.

▪ Disturbed areas and access roads watered

using a water cart/truck on an as-required

basis to minimise the potential for

environmental nuisance due to dust.

▪ Waste gas to be flared, unless otherwise

authorised.

▪ Appropriate siting of flare infrastructure

▪ Odour complaints shall be managed on a

complaints-based process in the first

instance and appropriate corrective actions

taken.

▪ Fugitive emissions mitigated through

appropriate well design and construction,

undertaken in accordance with an accepted

industry standard.

5.5 Risk assessment As discussed, there are two sensitive receptors in the form of temporary farm accommodation

located 1530 and 2467 metres (respectively) from the closest well proposed for stimulation. The

nature of the potential emissions (exhaust, combustion and fugitive), the duration of those

emissions and the distance from those receptors is such that any impact would be almost

undetectable. Dust impacts to the sensitive receptors would also be extremely low given the

distance to those receptors and the location of those receptors being a considerable distance from

trafficable areas.

Armour has determined that the likelihood rating of 1 for impacts to air environmental values as

there would only be circumstances of such impacts occurring under conditions and circumstances

for PL 511.The consequence of impacts to air values has been determined as being minor as there

would only ever be limited damage with little or no environmental harm. Thus, the residual risk

score (based on the likelihood and consequence rating) is categorised as rare.

6. LAND

6.1 Existing environment

6.1.1 General PL 511 is located in the Surat Basin, approximately 50 km south of Roma to 35 km south east of

Surat. PL 511 is made up of 14 sub-blocks; CHAR 2655 N, O, Q, R, S, T, V, W, X, Y and CHAR 2654 T, U,

Y, and Z. Real property descriptions for PL 511 are provided in Table 6-1.

Table 6-1 Real property descriptions for PL 511

Lot Plan Status

Lot 31 Plan WAL53599 Freehold





Lot 4 Plan E531 Freehold


Lot 1 Plan RP51181 Freehold

Lot 2 Plan RP51181 Freehold


Lot 55 Plan E531 Reserve

More than 75% of PL 511 is mapped as Strategic Cropping Land (an “area of regional interest” under

the Regional Planning Interests Act). There are no other areas of regional interest located within the

Production Area.

6.1.2 Geology PL 511 is directly underlain by the lower GAB formations of the Surat Basin (Hutton, Evergreen and

Precipice Sandstone) and the GAB formations of the upper Bowen Basin (Moolayember, Clematis

Sandstone).

The underlying Surat Basin geology is considered non-productive for PL 511 and well casing will pass

through these formations as they will not be targeted. The gas bearing formations of interest to

Armour are the Rewan (Triassic) and to a lesser extent, the Bandanna Formation from the

Blackwater Group, Tinowon Sands (Bowen Basin, Late Permian), and the Early Permian Cattle Creek

Formations (if present). These hydrocarbon-bearing formations are located below the local Snake

Creek Shale seal and at a depth greater than 1800 metres. It should be noted that the Clematis is

hydrocarbon and/or water charged in PL 511 i.e. a water drive.

A summary of the major formations located between surface and target formations are described

(from upper to lower) below:

▪ Wallumbilla Formation: The Wallumbilla Formation is a Lower Cretaceous geologic formation

found in Australia. It is a sedimentary unit, principally made up of marine grey mudstone and

siltstone with minor interbeds of fine-grained glauconitic and calcareous sandstone, local thin

micritic limestone beds and heavy mineral strandline accumulations; down-sequence glacial ice-

rafted erratics. Its maximum thickness is 600 metres.

▪ Bungil Formation: overlies the Mooga Sandstone, and consists of lacustrine, deltaic, and shallow

marine fine-grained sediments, including glauconitic, labile to quartzose, siltstone, mudstone,

and minor thin coal seam. The Bungil Formation contains subdominant coarse-grained quartzose

sandstone in some areas.

▪ Mooga Sandstone: overlies the Orallo Formation. This Cretaceous age unit consists largely of

clean fluviatile and lacustrine sandstone and siltstone. The Mooga Sandstone comprises

quartzose, sub-labile sandstone, minor siltstone, shale, mudstone and coal, which were

deposited in swamp environments.

▪ Orallo Formation: Thinly bedded sandstone, siltstone, mudstone, conglomerate, coal, and fossil

wood conformably overlying the Gubberamunda Sandstone. The Orallo Formation contains tuff,

which has weathered to bentonite and the sandstone contains abundant andesitic volcanic

detritus (Exon, 1971).

▪ Gubberamunda Sandstone: deposited by stream and lakes, comprises sandstone, minor

conglomerate, and siltstone. Estimated to be approximately 100 m thick (GSQ, 1964), and

contains marine fauna of Aptian age (125 Ma to 113 Ma Late Jurassic).

▪ Westbourne Formation: The fluvial-lacustrine sediments of the Westbourne Formation overlie

the Springbok Sandstone. These sediments include fine-grained sandstone interbedded with

siltstone, claystone, and minor coal. This regional aquitard has a maximum thickness of 220 m

and separates the Springbok Sandstone and the Gubberamunda Sandstone;

▪ Springbok Sandstone: comprising clayey lithic sub-labile to very lithic sandstone, which is

calcareous in parts. The sandstone is interbedded with carbonaceous mudstone and siltstone;

▪ Walloon Coal Measures: The Walloon Coal Measures are reported to be up to 650 m thick (Exon,

1976). The formation consists of sandstone, siltstone, carbonaceous mudstone and coal, and lies

conformably over the underlying Hutton or Marburg Sandstones. The coal seams vary in both

thickness and quality, and often appear to not continuous.

▪ Hutton Sandstone: Early to Middle Jurassic age unit. Poorly sorted, coarse to medium-grained,

feldspathic sublabile sandstone (at base) and fine-grained, well-sorted quartzose sandstone (at

top); minor carbonaceous siltstone, mudstone, coal and rare pebble conglomerate.

▪ Evergreen Formation: Conformably overlies Precipice Sandstone and part unconformably

overlies Chahpingah Meta-Igneous Complex and underlying the Precipice Sandstone. The

Evergreen Formation includes the former "Evergreen Shales" and Boxvale Sandstone as a

member. Labile and sublabile, sandstone overlain by carbonaceous mudstone, siltstone and

minor coal; local oolitic ironstone.

▪ Precipice Sandstone: Late Triassic unit. Thick-bedded, cross-bedded, pebbly quartzose

sandstone, minor lithic sublabile sandstone, siltstone, mudstone. The Precipice Sandstone is a

hydrocarbon reservoir and deep, high-quality aquifer in the Great Artesian Basin (GAB).

▪ Moolayember Formation: Late Triassic to Anisian aged unit. Overlies the Precipice Sandstone

and has a maximum thickness of 736 metres. Micaceous lithic sandstone, micaceous siltstone.

Lacustrine mudstones from the Moolayember Formation (i.e. Snake Creek Mudstone) form a

regional seal for the underlying Showgrounds Sandstone and Rewan Formation.

▪ Snake Creek Mudstone Member: Middle Triassic unit overlying the Clematis and Showground

Sandstones. Predominantly dark grey to black mudstone with minor laminae and thin beds of

very fine-grained sandstone

▪ Clematis Group: Medium to coarse-grained quartzose to sublabile, micaceous sandstone,

siltstone, mudstone and granule to pebble conglomerate

▪ Showground Sandstone: Anisian aged unit with a maximum thickness of 13 metres. Consists of

white coarse quartzose sandstone.

▪ Rewan Formation: Early Triassic to Wuchiapingian aged unit. Lithic sandstone, pebbly lithic

sandstone, green to reddish brown mudstone and minor volcanilithic pebble conglomerate (at

base); deposited in a fluvial-lacustrine environment.

▪ Bandanna Formation: Mudstone, siltstone, sandstone and coal. Laminated to massively bedded

labile sandstone, interbedded with mudstones and siltstones. Reportedly high gas content (10-

15 m3 per tonne). CSG is extracted from these seams at Spring Gully gas field where there is high

gas content and good permeability.

▪ Tinowon Sands: Late-Permian aged unit. Shale, siltstone, quartzose sandstone, tuff, coal.

Includes glacial diamictites.

6.1.2.1 Faulting The southern part of PL 511 is located near the western margin of the Surat Basin, south of Roma. In

this area, the main geological units do not indicate deformation or complex faulted geology. Some

large structural features are visible in the outcrop including the Alicker and Eurombah Anticlines, the

Hutton-Wallumbilla Fault and a number of west north-west trending faults.

The north-west trending Hutton-Wallumbilla Fault is located west of Roma and is downthrown to

the west with a displacement of ~450 m in the basement but just 30 m in the overlying sediments.

Other small north-west trending faults are likely related to the movements that formed the Hutton-

Wallumbilla Fault (Scott, 2004). These faults are also likely a result of epeirogenic movements (the

gradual uplift or subsidence of the Earth's surface) related to the Surat Basin through the Tertiary

period (Scott, 2004). These faults have limited or no vertical displacement but they leave a clearer

topographic imprint than the larger faults in the same region due to their younger age.

Predominately all of the Permian-Triassic folds are truncated by the erosional unconformity surface.

The overlying Jurassic and Cainozoic rocks are not folded (Scott, 2004). The Permian and Triassic

sequence of sediments was folded principally during the late Triassic Period.

The central part of PL 511 is situated between two large reverse fault systems that are oriented

approximately north south. Immediately to the east of Surat is an anticline, which plunges to the

south-southeast and corresponds to a southerly extension of the Balonne Nose in the geological

basement.

Figure 6-1 Local and regional stratigraphy underlying PL 511

6.1.3 Soils and land units Soil types in the Surat Region are predominantly red earth and red brown earth with some black clay

soils. The landform is best described as gently undulating plains (1 to 2%) and short slopes of 5%

associated with ridges and crests. The soils are considered vulnerable to sheet, rill and gully erosion,

particularly where large areas have been cleared to expose soil in the interest of grazing capability or

preparation of cropping. A summary of land units and dominant soil types is provided in Table 6-3.

Table 6-2 Land Units and Dominant Soil Types

Government mapping code

Concept Dominant soils Australian Soil Classification

Balonne Maranoa

(S)rNi Rises and low hills; narrow leaved ironbark woodland with shrubs; shallow, stony massive earths.

Dark brown and grey-brown soils: shallow to moderately deep (40-90 cm) uniform light to heavy clay soils, with strongly alkaline subsoils.

Dark brown and grey-brown Vertosols and Dermosols

(S)uBl Lowlands; belah or brigalow open forest; duplex soil and cracking clays with some gilgai.

Texture contrast soils: 85-120 cm deep, underlain by weathered zone; thin loamy, slightly acid surface horizons over strongly acid blocky subsoils.

Kurosols and Chromosols

(S)uX Lowlands; belah or brigalow open forest; duplex soil and cracking clays with some gilgai.

Shallow brown and grey-brown clay soils: <60 cm deep. Some surface rock.

Shallow brown and grey-brown Vertosols and Chromosols

AX Lowlands; belah or brigalow open forest; duplex soil and cracking clays with some gilgai.

Deep texture-contrast soils: thin sandy or loamy surface horizons over strongly alkaline to acid subsoils. Some alkaline dark grey to brown cracking clays.

Sodosols, Chromosols, and alkaline dark grey to brown Vertosols

QrCp Rolling and undulating terrain; cypress pine open forest; uniform sandy soils and duplex soils with thick sandy surface horizons.

Skeletal soils: very shallow (<30 cm) sandy and gravelly, some minor shallow texture-contrast soils on some lower slopes.

Rudosols, Chromosols and Sodosols

ShSw Hills and escarpments; softwood scrub; brown and grey-brown soils.

Uniform sandy soils: mainly shallow (<60 cm); some deep soils (>90 cm), medium acid throughout.

Tenosols and Kandosols

Government mapping code

Concept Dominant soils Australian Soil Classification

SrX Rolling terrain; poplar box and silver leaved ironbark woodland; brown and grey-brown soils.

Uniform sandy soils: mainly >150 cm deep, yellowish brown to brown.

Deep Tenosols and Kandosols

There are no known acid-sulfate soil-prone areas or acid-bearing rock formations within the vicinity

of PL 511.

6.1.4 Climate The mean daily temperatures range for the Surat Basin is from 27°C to 30°C in February and 10°C to

14°C in July. Temperatures greater than 40°C are moderately common in summer. Winds are

generally west to south-westerly in autumn and winter and vary from north easterly to south

easterly in spring and summer.

An overview of the climatic extremes as recorded by the Bureau of Meteorology (BoM) at the

nearest meteorological station, Roma Airport, between the years 1985 to 2017 indicate:

▪ annual average rainfall of 579.2 mm, with average maximum rainfall of 86.7 mm in February and

average minimum rainfall of 22.8 mm in July;

▪ average maximum temperature of 34.3°C in January and average minimum temperature of 3.8°C

in July; and

▪ average maximum 9am humidity of 73% in June and average minimum 3pm humidity of 27% in

September.

6.1.5 Land Use Land use associated within the Maranoa Shire Council is predominantly cattle and sheep grazing (for

beef and wool respectively) while limited cereal and fodder cropping is also undertaken. A number

of other agribusinesses contribute significantly to the local community, from heavy machinery

through to agronomy services.

Other land uses include urban, industrial, CSG and conventional petroleum and gas extraction and

mining (mainly coal) although there are no overlapping tenures for PL 511.

6.2 Description of environmental values There are no prescribed environmental values relating to land for PL 511. Based on the assessment

of the existing environment the environmental values of the land within PL 511 to be protected or

enhanced are:

▪ the geological stability of landscape;

▪ soil health and function, including the physical and chemical attributes of soil, relative to

propagation and growth of vegetation;

▪ the integrity of soil stability and structure for erosion protection; and

▪ the suitability of the land for continued agricultural use (grazing and cropping) post-closure.

6.3 Emissions and releases There are no expected emissions or releases to the identified land environmental values associated

specifically with this amendment, although an unplanned release of stimulation fluids and chemicals

would have the potential to impact on land values.

6.4 Likely impacts and proposed management practices Hydraulic stimulation and ancillary activities have a range of potential impacts upon terrestrial

environmental values, specifically:

▪ improper storage and handling of fuel, chemicals and flowback fluids has the potential to result

in localised contamination of soil;

▪ livestock interaction with stimulation fluid and flowback containment systems;

▪ induced seismicity has the potential to occur as a result of improper hydraulic stimulation of

wells; and

▪ land subsidence as a result of improper hydraulic stimulation of wells.

6.4.1 Chemical and flowback fluid storage Unplanned release of chemicals has the potential to impact on the surrounding environment in

PL 511. To avoid spillage and environmental impacts, all chemicals will be stored and handled in

accordance with the relevant legislative requirements and Australian Standard (AS) including:

▪ AS 3780:2008 – The storage and handling of corrosive substances;

▪ AS 1940:2004 – The storage and handling of flammable and combustible liquids;

▪ AS 3833:2007 – Storage and handling of mixed classes of dangerous goods in packaged and

intermediate bulk containers; and

▪ Waste Reduction and Recycling Act 2011.

A suitable location for temporary chemical storage shall be determined in accordance with an

appropriate constraints analysis. This would involve a review of GIS mapping layers to identify any

environmental or other constraints identified and choosing an appropriate storage location that will

avoid or minimise the impacts on environmental values wherever possible.

Armour may also engage with landholders to identify on-ground constraints and to confirm

preferred location(s) for temporary storage.

In the unlikely event that spillage does occur, clean-up shall be undertaken in accordance with the

Surat Operations Environmental Management Plan and Site Emergency Response Plan - Surat Basin.

6.4.2 Livestock interactions with stimulation fluid Modular, prefabricated tank storage systems that can be deconstructed and removed with minimal

impact on the environment shall be utilised for temporary stimulation fluid and flowback storage.

Tank construction is typically solid steel framing and lined with geotextile and polyethylene material

and is engineered and certified to meet Australian Standards.

Measures such as regular monitoring of the structure, liner, and operating conditions (for example,

sufficient freeboard, liner and fencing integrity) may be undertaken to prevent livestock access to

tank contents.

6.4.3 Induced seismicity and subsidence Certain literature from overseas suggests a potential for hydraulic stimulation activities to cause

localised induced seismicity. However, the risk of this occurring is extremely low and under specific

circumstances, and the resultant seismic events virtually undetectable without specialist equipment.

Much of the induced seismicity that has been detected overseas is attributable to the re-injection of

produced wastewater and not as a result of hydraulic stimulation of wells.

Land subsidence could theoretically occur where significant volumes groundwater and gas are

extracted from reservoirs and the reduction in water pressure may result in compaction of the

geological units in which depressurisation has occurred. However, the potential for this to occur in

PL 511 is negligible as the target formation are so deep and there will be no dewatering to relieve

reservoir pressure. A comprehensive analysis by other proponents suggests that the subsidence

impact from operations is likely to be undetectable from background landscape movement, and

therefore the risk of damage to infrastructure is anticipated to be low (Australian Government,

2014).

Table 6-3 Land - Likely Impacts and Key Management Practices


▪ Improper storage and handling of fuel, chemicals and flowback fluids has the potential to result in localised contamination of soil

▪ Livestock interactions with stimulation fluid

▪ Road usage

▪ Induced seismicity

▪ Land subsidence

▪ Stimulation additives stored in accordance with relevant industry standards and legislative requirements, and managed per the Surat Operations Environmental Management Plan

▪ Spillage managed in accordance with the Surat Operations Environmental Management Plan and Site Emergency Response Plan - Surat Basin”

▪ Where necessary, appropriate monitoring and infrastructure (e.g. fencing) to effectively exclude livestock from contact with stimulation fluid


▪ No specific management required. Induced seismicity highly unlikely in target formations/depths.

▪ No specific management required as analysis by other proponents indicates that the subsidence impact from stimulation operations is likely to be undetectable from background landscape movement (Australian Government, 2014).

6.5 Risk assessment The management practices offer effective controls to manage the likely impacts to the land profile

and soil properties associated with the proposed activities in PL 511.

Armour has determined that the likelihood rating for impacts to land environmental values of 1, as

there would only be limited circumstances under which such impacts could occur, and the resultant

consequences of those impacts would be minor.

In the unlikely event of a containment breach that results in the release of stimulation chemicals,

stimulation fluid or flowback into the surrounding environment, Armour anticipates that the impact

would be low, and that the duration of any such impact would be negligible, therefore the

consequence of those impacts has been determined as being minor. Thus, risk score is based on the

likelihood and consequence rating is categorised as rare.

7. NATURAL ENVIRONMENT

7.1 Existing environment PL 511 is located within the Queensland Brigalow Belt South bioregion. Native vegetation of the

bioregion is characterised by woodland and forest communities of Acacia harpophylla (Brigalow)

with scattered ecosystems dominated by eucalypt species, cypress pine, acacia species and

grassland (Sattler and Williams, 1999).

Local vegetation predominantly consists of grassy open woodland of Poplar Box, Silverleaf Ironbark

with Sandalwood understory and some Cyprus Pine. Scattered patches of Brigalow and Belah occur.

There are some endangered regional ecosystems “of concern” regional ecosystems (Category “C”

ESA) located within PL 511.

Much of the surrounding area has been extensively cleared for grazing and cropping activities, whilst

remnant vegetation within PL 511 is generally confined to waterway riparian zones. A summary of

terrestrial habitat types located in PL 511 is provided in Table 7-1. There are no protected plants

triggered within PL 511.

Table 7-1 Terrestrial habitat types located in PL 511

Description Biodiversity status Description

11.9.3 No concern at

present

Grassland dominated by Dichanthium sericeum

and/or Astrebla spp. (A. lappacea, A. elymoides

and A. squarrosa) but contains large numbers

of short-lived perennial grasses, annual grasses

and annual forbs, which may dominant

depending on seasonal conditions and

management regime.

11.9.3a/11.9.14 No concern at

present/ of concern

Eucalyptus spp., and/or Acacia spp. Open

woodland. Typical species include Eucalyptus

melanophloia, E. orgadophila, Corymbia

erythrophloia, Lysiphyllum carronii, Atalaya

hemiglauca, Acacia pendula, A. omalophylla

and Geijera parviflora.

Lysiphyllum carronii, Atalaya hemiglauca +/-

Eucalyptus melanophloia +/- Acacia open

woodland

11.3.3 Of concern Eucalyptus coolabah open woodland to

woodland with a grassy understorey. A mid

layer is often absent but scattered tree or shrub

species, such as E. populnea, Melaleuca

bracteata, Acacia stenophylla, Alectryon

oleifolius, Terminalia oblongata (in the north)

and Acacia pendula, A. cambagei, and

occasionally Duma florulenta may be present.

Desktop sources identified the potential presence of eleven species listed as endangered, vulnerable

or near threatened fauna species (Table 7-2).

Table 7-2 Threatened Species Confirmed or Possible to Occur within PL 511

Species Common Name Status

(EPBC/NCA)

Likelihood of

Occurrence Category

Calidris ferruginea Curlew sandpiper NCA – EPBC – CE

May occur

Geophaps scripta Squatter pigeon (southern) NCA – VU

EPBC – VU

May occur

Grantiella picta Painted honeyeater NCA – VU

EPBC – VU

May occur

Rostratula australis Australian painted snipe NCA – VU

EPBC – EN

May occur

Nyctophilus corbeni South-eastern long-eared bat NCA – VU

EPBC – VU

May occur

Maccullochella peelii Murray Cod NCA – VU EPBC – VU

May occur

Phascolarctos cinereus Koala NCA – VU

EPBC – VU

May occur

Delma torquata Collared delma NCA – VU

EPBC – VU

May occur

Egernia rugosa Yakka skink NCA – VU

EPBC – VU

May occur

Furina dunmalli Dunmall’s snake NCA – VU

EPBC – VU

May occur

Dichanthium setosum Bluegrass NCA – VU

EPBC – VU

May occur

7.2 Description of environmental values There are no prescribed environmental values relating to the natural environment for PL 511.

Nonetheless, Armour considers that, consistent with the EP Act, the “Central Queensland Strategy

for Sustainability: 2004 and Beyond” and the “Natural Resource Management Ministerial Council

(NRMMC) National Objectives”, the environmental values for PL 511 are:

▪ the protection and enhancement of regional biodiversity and supporting ecological processes;

and

▪ protection of populations of significant species and ecological communities.

7.3 Emissions and releases There are no expected emissions or releases to the identified natural environment environmental

values.

7.4 Likely impacts and proposed management practices The potential impacts to flora and fauna during the proposed hydraulic stimulation activities include:

▪ Inadvertent ignition of vegetation from Armour’s activities;

▪ Fauna injury of damage to flora from fire.

▪ Introduction of weeds and pests;

▪ Flora or fauna harm by contact with inappropriately stored substances;

▪ Fauna injury from vehicle strike; and

7.4.1 Fire management Fire extinguishers will be fitted to all vehicles. Personnel will be made aware of fire restrictions and

fire weather information as required. Smoking will be prohibited except in designated areas with

proper receptacles. Where necessary, a Bushfire Management Plan shall be developed for the Surat

operations and actions coordinated with neighbours and other stakeholders.

All fire-fighting equipment will be maintained in good working order and personnel will be trained in

the use of this equipment and notified of nearby available sources of water

The fire prevention requirements during high fire risk periods will include a bare earth firebreak with

a five-metre radius from a hot work area, fire-fighting equipment and stopping work during extreme

weather conditions. Fire management shall be undertaken in accordance with the Surat Operations

Environmental Management Plan and Site Emergency Response Plan - Surat Basin.

7.4.2 Translocation of pests Armour’s weed management procedures and practices aim to achieve consistency with the strategic

goals of relevant Council Plans and industry weed advisory guidelines.

Declared weeds in PL 511 may include Galvanised Burr, Bathurst Burr, Pimelea and Japanese

Sunflower. Other priority weed species include Parthenium Weed, Mother of Millions, Harrisia

Cactus and African Boxthorn.

Measures to minimise the spread of weeds include:

▪ Incorporating weed management requirements into contracts and planning documents;

▪ Educating personnel and contractors on the requirements of managing weeds;

▪ Carrying out weed monitoring and eradication reporting;

▪ Conducting washdowns and vehicle inspections;

▪ Vehicles travelling into the Surat development area will undergo a risk-based assessment to

determine whether they pose a weed transmission risk (i.e. the presence of weed seed or

excessive mud).

▪ Vehicles will be directed to approved washdown facilities as appropriate whereby vehicles will

be issued with Washdown Certificates or Weed Hygiene Certificates upon treatment and must

only travel on nominated tracks and roads when travelling within the project area.

▪ Daily movements of vehicles will be planned to minimise transit between properties and overall

vehicle movements to reduce the risk of the vehicles coming in to contact with potential weeds.

Vehicles will not be allowed access beyond the approved and designated areas, access roads and

tracks. Access to the development area will only be allowed from approved access routes.

In the unlikely event that weeds are introduced or exacerbated due to the activities undertaken,

follow up weed control will be undertaken per the Surat Operations Environmental Management

Plan.

7.4.3 Appropriate chemical storage As previously discussed, unplanned release of chemicals has the potential to impact on the natural

environment. All chemicals will be stored and handled in accordance with the relevant legislative

requirements and Australian Standard (AS) including:

▪ AS 3780:2008 – The storage and handling of corrosive substances;

▪ AS 1940:2004 – The storage and handling of flammable and combustible liquids;

▪ AS 3833:2007 – Storage and handling of mixed classes of dangerous goods in packaged and

intermediate bulk containers; and

▪ Waste Reduction and Recycling Act 2011.

A suitable location for temporary chemical storage shall be determined in accordance with an

appropriate constraints analysis. This would involve a review of GIS mapping layers to identify any

environmental or other constraints identified and choosing an appropriate storage location that will

avoid or minimise the impacts on environmental values wherever possible.


preferred location(s) for temporary storage. In the unlikely event that spillage does occur, clean-up

shall be undertaken in accordance with the Surat Operations Environmental Management Plan and

Site Emergency Response Plan - Surat Basin.

7.4.4 Vehicle strike The increase in activity within PL 511 will result in an increase in road usage and vehicle movements,

and consequently increased risk of striking native fauna during low light periods. To mitigate this risk

to the greatest possible extent, Armour shall consider developing a journey management procedure

to ensure that strict speed limits are enforced on internal roads and, wherever possible, vehicle

movements are avoided during low light periods. Armour will also limit hydraulic stimulation

activities to daylight hours.

Table 7-3 Natural environment - likely impacts and key management practices


▪ Risk of bushfire from operation of stimulation equipment

▪ Inadvertent translocation of pests

▪ Preservation of native vegetation

▪ Spillage of fuels, chemicals and flowback fluids adversely affecting native flora and fauna

▪ Vehicle strike impacting on native fauna populations

▪ Development of a Bushfire Management Plan as required.

▪ Vehicles travelling into the Surat development area will undergo a risk-based assessment and directed to approved washdown facilities, as appropriate

▪ Clearing of vegetation minimised to the

greatest extent practicable

▪ Stimulation additives stored in accordance with relevant industry standards and legislative requirements

▪ Where necessary, develop a journey

management procedure to ensure that strict speed limits are enforced on internal roads and, wherever possible, vehicle movements are avoided during low light periods to avoid fauna strike

▪ Stimulation activities only conducted during

daylight hours.

▪ Application of management practices outlined in Surat Operations Environmental Management Plan and Site Emergency Response Plan - Surat Basin.

7.5 Risk assessment The magnitude and severity of potential impacts has been determined based on technical

assessments carried out by suitably qualified and experienced specialists. Implementation of the

aforementioned management practices will minimise the extent of impacts to flora and fauna.

Indirect disturbances to terrestrial ecosystems relating to weeds and pests, displacement and

degradation of habitat, as well as potential for mortality of fauna, will be effectively managed by

implementing the environmental management practices outlined above.

Where impacts are unavoidable, Armour anticipates that those impacts will be localised, short-term

and recoverable and so the likelihood rating is 1. Furthermore, the consequence of those impacts

has been determined as being minor. As a result of implementing the management practices

outlined above, the risk score is categorised as rare, as the likelihood and consequences would only

arise in exceptional circumstances.

8. NOISE

8.1 Existing environment Environmental Impact Statement studies undertaken by Santos GLNG (2008) and APLNG (2009)

determined baseline noise values of the ambient and background noise environment within the

rural setting of the Surat and Bowen Basins (Savery and Associates, 2009).

Background noise in the aforementioned studies were dominated by bird calls and insect activity

and, at a number of monitoring locations in the GLNG study, discontinuous road traffic noise.

Consistent with the GLNG and APLNG studies in the region, the existing background noise

environment within the vicinity of PL 511 is typical of most rural areas with generally low levels of

background noise dominated by natural sounds and little or no road traffic.

Armour notes that noise measurements recorded during the GLNG and APLNG studies were

collected during the cooler winter months and represent worst case scenario conditions relating to

noise propagation. Conversely, throughout the warmer months, the baseline noise environment is

likely to contain additional insect noise.

No blasting activities are proposed and therefore no risk assessment has been undertaken for

potential vibration impacts upon sensitive receptors.

8.2 Description of environmental values The following environmental values are prescribed under the Environmental Protection (Noise)

Policy 2008:

▪ the qualities of the acoustic environment that are conducive to protecting the health and

biodiversity of ecosystems;

- the qualities of the acoustic environment that are conducive to human health and wellbeing,

including by ensuring a suitable acoustic environment for individuals to do any of the

following:

- sleep;

- study or learn;

- be involved in recreation, including relaxation and conversation, and

▪ the qualities of the acoustic environment those are conducive to protecting the amenity of the

community.

8.3 Emissions and releases Stimulation activities will be undertaken for a fixed period of time and noise will be generated daily

during that period for each well (up to five wells in total). As a result, individual sensitive receptors

are likely to be exposed to additional noise emissions from these activities for a week at a time (i.e.

expected duration of each well stimulation).

Armour anticipates that its hydraulic stimulation campaign will be materially similar to that of Santos

GLNG in respect to overall design and equipment. It is noted that Santos GLNG had previously

identified and provided to EHP the following typical noise source values for key well stimulation

apparatus:1

▪ Annulus – 1 off – SWL 90.3 dB(A)

▪ Stim Van – 1 off – SWL 98.8 dB(A)

▪ Power Pack – 1 off – SWL 106.7 dB(A)

▪ High pressure pump – 4 off – SWL 104.7-107.6 dB(A) – average SWL 106.1 dB(A)

▪ Low pressure pump – 1 off – 99.5 dB(A)

▪ Downhole Blender – 1 off – SWL 105.4 dB(A)

▪ Sand trailer – 1 off - SWL 100.2 dB(A)

▪ Pregel – 1 off – SWL 104.6 dB(A)

▪ LGC – 1 off – SWL 97.9 dB(A).

According to GLNG, the added noise sources provide a conservative, estimated of total noise

emissions of SWL 115 dB(A)( assuming that all noise sources are operational at full load at the same

time) and that, under neutral meteorological conditions, noise levels in the region of 50 dB LAeq 1-

hour could be expected at a distance of 500 m from the hydraulic stimulation spread, and further

reducing to falling 45 dB LAeq 1- hour at 1 km, 40 dB LAeq 1- hour at 2 km and about 35 dB LAeq 1-

hour at 4 km.2

The estimated noise levels over distance are based conservatively on the simultaneous operation of

all noise sources, and lower levels would be generated if some or all of the identified equipment

were to be operated sequentially or intermittently.

The two identified sensitive receptors are located 1530 and 2467 metres (respectively) from the

closest well proposed for stimulation. Armour anticipates that the unattenuated noise emissions at

the closest sensitive receptor will be somewhere in the magnitude of 42-43 dB (LAeq 1 – hour)

during daylight hours and for a duration of seven days or less.

8.4 Likely impacts and proposed management practices The proposed stimulation activities have the potential to impact on acoustic environmental values

(subject to separation distances to sensitive receptors, the level and duration of the noise, and the

time of day that the noise occurs).

Armour manages noise emissions in accordance with the hierarchy in the Noise EPP (avoid,

minimise, manage). Armour will preferentially locate nuisance sources away from near sensitive

receptors and will utilise equipment that minimises the sources of environmental nuisance.

Armour shall also endeavour to implement the noise control strategies proposed in the Surat

Operations Environmental Management Plan.

1 https://www.santos.com/media/3778/glng-upstream-hydraulic-frac-risk-assessment-compendium-of-assessed-fluid-systems.pdf 2 https://www.santos.com/media/3778/glng-upstream-hydraulic-frac-risk-assessment-compendium-of-assessed-fluid-systems.pdf

Table 8-1 Noise- Likely impacts and key management practices


• Ground-borne noise

• Impacts associated with well stimulation

that has the potential to cause nuisance to

sensitive receptors.

• Prior to stimulation activities, landholders

and owners of any adjacent sensitive places

will be notified of the nature and expected

duration of noisy activities.

• Noise generating activities associated with

well stimulation will be in accordance with

EA conditions and requirements of the

Environmental Protection (Noise) Policy

2008 (EPP Noise).

• Noise impacts will be minimised by

adopting measures in the EPP Noise

hierarchy as appropriate

• Operators of equipment will be aware of

potential noise impacts and be required to

employ techniques and/or equipment to

minimise noise emissions as applicable.

• Noise management measures implemented

per the Surat Operations Environmental

Management Plan.

8.5 Risk assessment Armour proposes to hydraulically stimulate up to five wells that are located varying distances from

sensitive receptors with the nearest sensitive receptor approximately 1.5 lateral kilometres away.

Hydraulic stimulation activities will not be conducted outside of daylight hours in order to minimise

noise impacts at sensitive receptors and minimise safety risks for personnel and contractors.

Anticipated duration for hydraulic stimulation activities is seven days or less for each well.

As discussed, estimated total noise emissions for hydraulic stimulation (with all noise sources

operational) will be approximately SWL 115 dB(A). Under neutral meteorological conditions, noise

levels in the region of 50 dB LAeq 1- hour could be expected at a distance of 500 metres from the

hydraulic stimulation spread, and further reducing to falling 45 dB LAeq 1- hour at 1 kilometre, 40 dB

LAeq 1- hour at 2 kilometres.

Armour anticipates that the unattenuated noise emissions at the closest sensitive receptor will be

somewhere in the magnitude of 42-43 dB (LAeg 1 – hour) during daylight hours and for a duration of

seven days or less. Nosie emissions of this magnitude are consistent with medium-term noise events

(see Table 8-2).

Armour has compared these calculated acoustic emissions with the EHP guideline, Noise Assessment

- Prescribing Noise Conditions for Environmental Authorities for Petroleum and Gas Activities ‘best

practice’ noise limits for the preservation of acoustic environmental values of a noise receptor in

rural or isolated areas (Noise Assessment Guideline) (see Table 8-2).

Implementation of the aforementioned management practices will minimise the extent of impacts

to noise sensitive receptors and the likelihood of adverse impacts upon acoustic environmental

values is rated as 1. The consequence of those impacts has been determined as being minor. As a

result of implementing the management practices outlined above, the risk score is categorised as

rare, as the likelihood and consequences would only arise in exceptional circumstances.

Table 8-2 Best practice noise emission limits for oil and gas

Time Period Parameter Noise Limit (dBA)7

Short-term* Medium-term** Long-term***

7:00 am – 6:00 pm LAeq, adj, 15mins 45 43 40

6:00 pm – 10:00 pm LAeq, adj, 15mins 40 38 35

10:00 pm – 6:00 am LAeq, adj, 15mins 28 28 28

Max LpA, 15 mins 55 55 55

6:00 am – 7:00 am LAeq, adj, 15mins 40 38 35

*A short-term noise event is a noise exposure, when perceived at a receptor premise, which persists

for an aggregate period not greater than eight hours and does not re-occur for a period of at least

seven days.

**A medium-term noise event is a noise exposure, when perceived at a receptor premise, which

persists for an aggregate period not greater than five days and does not re-occur for a period of at

least four weeks.

***A long-term noise event is a noise exposure, when perceived at a receptor premise, which

persists for a period of greater than five days, even when there are respite periods when the noise is

inaudible within those five days.

9. COMMUNITY

9.1 Existing environment PL 511 is located in the Maranoa Regional Council area which is home to approximately 13,000

people. More than half of the population lives within the township of Roma (est. 6,950) which is a

highly-urbanised centre and acts as the region’s primary hub for commerce, education, health,

transport, government, retail and financial services. In recent times the region has become a hub for

the coal seam gas industry.

9.2 Description of environmental values Although there are no prescribed community environmental values for PL 511, environmental values

of importance to the local community exist, and require due consideration. These values include:

▪ the overall amenity, liveability and sense of community supported by profitable local businesses;

▪ access to social, community services and infrastructure in the region surrounding PL 511

(including economic conditions and benefits within the affected community); and

▪ the qualities of the land that are conducive to human health and wellbeing.

9.3 Emissions and releases As discussed, the proposed activities will generate the following emissions that may impact upon the

local community:

▪ exhaust fumes from operation of hydraulic stimulation equipment, and venting or flaring of gas

(see Section 5.4.2);

▪ dust generated by machinery and equipment usage and vehicle movements (see Section 5.4.1);

▪ fugitive emissions from well heads and associated infrastructure (see Section 5.4.3); and

▪ noise emissions associated (see section 7.4).

9.4 Likely impacts and proposed management practices There will be a minor impact upon accommodation availability during the proposed activities as the

well stimulation service provider will not be utilising an onsite camp. Instead, accommodation will be

sourced in Surat during that period of time.

The environmental management and mitigation measures proposed for community environmental

values are summarised in Table 9-1.

Table 9-1 Community - Likely impacts and key management practices


▪ Impacts/co-existence with existing

landholder activities;

▪ Additional pressure on local housing and

accommodation availability;

▪ Nuisance impacts (light, noise, dust) (see

Tables 5-1 and 7-1);

▪ Cumulative impacts on community services

(e.g. - recreation facilities, service hire

availability, etc.), product availability (food,

petrol, personal items, etc.), and

infrastructure;

▪ Fugitive emissions

▪ Preferentially locating infrastructure to

minimise visual and nuisance impacts and

to protect environmental values;

▪ Develop and maintain a complaints

management system ensuring, where

practicable, issues and/or complaints are

appropriately addressed;

▪ Develop and implement policies relating

to service provision and purchasing

hierarchies (e.g. local personnel and

business first if suitably qualified and

commercially competitive); and

▪ Adherence to all Conduct and

Compensation Agreements and the Land

Access Code and Surat Operations

Environmental Management Plan for all

dealings with landholders.

▪ Fugitive emissions mitigated through

appropriate well design and construction,

undertaken in accordance with an

accepted industry standard.

Armour recognises the benefits that can be achieved from community engagement and consultation

and is committed to developing and maintaining community engagement to maintain good

relationships and social licence during the proposed activities. Furthermore, Armour will take all

practicable measures to comply with Conduct and Compensation Agreements and the Land Access

Code for all dealings with landholders and ensuring appropriate onsite behaviour by Armour

personnel and contractors.

9.5 Risk assessment While there are no prescribed community environmental values, Armour will implement a suite of

management practices to minimise impacts to the community.

Given the rural location, the preferential siting of temporary equipment and infrastructure during

the stimulation activities, and the typically large distances to most residences, the likelihood rating

of 1 for impacts to community environmental values as there would only be circumstances of such

impacts occurring under conditions and circumstances for PL 511.

The consequence of impacts to community values has been determined as being minor as there

would only ever be limited damage with little or no environmental harm. Thus, risk score is based on

the likelihood and consequence rating is categorised as rare.

10. HERITAGE

10.1 Existing environment Department of Aboriginal and Torres Strait Islander Partnerships records indicate two culturally

significant Mandandanji sites within PL 511; a shell midden scatter, and an artefact scatter (DATSIP,

2018). A further culturally significant artefact scatter is located to the south-west, outside of the

tenure boundary (DATSIP, 2018).

There are no recorded non-indigenous cultural heritage sites or artefacts within PL 511.

10.2 Description of environmental values The following environmental values are relevant for indigenous and non-indigenous heritage within

PL 511:

▪ Cultural and spiritual values of the land; and

▪ Qualities of the land that are conducive to protecting the aesthetics of the environment,

including the appearance of culturally significant buildings, structures and other property.

10.3 Emissions and releases Proposed activities result in the inadvertent spillage of stimulation fluid or flowback proximate or

within heritage site perimeters.

10.4 Likely impacts and proposed management practices There is the potential for culturally significant artefacts and sites to be impacted by stimulation

activities within PL 511 via:

▪ disturbance of known heritage sites or artefacts during stimulation activities; and

▪ discovery of new sites or artefacts.

Armour has a "duty of care" to ensure that it has appropriate measures in place in order to

demonstrate that it has taken all reasonable and practical measures to ensure their activities do not

harm cultural heritage.

Stimulation activities shall be conducted in a manner that avoids, or minimises to the greatest extent

possible, impacts upon cultural heritage values. Where necessary, additional cultural heritage

surveys will be undertaken with the assistance of a qualified archaeologist and local traditional

owners prior to any works commencing.

Heritage register searches shall be undertaken prior to land disturbance activities. No works should

be undertaken or access permitted within areas marked as cultural heritage ‘no go’ areas.

For new discoveries, the Site Supervisor must be notified immediately if any cultural heritage sites,

objects or remains are located. Should this occur, work must cease immediately.

The environmental management and mitigation measures proposed for heritage values are

summarised in Table 10-1.

Table 10-1 Heritage - Likely impacts and key management practices


▪ Locating stimulation equipment proximate

or within heritage site perimeters.

▪ Disturbing indigenous and non-indigenous

heritage sites during stimulation activities.

▪ Discovering further heritage material.

▪ No works are to be undertaken or access

permitted within areas marked as cultural

heritage ‘no go’ areas.

▪ The Site Supervisor must be notified

immediately if any cultural heritage sites,

objects or remains are located. Should this

occur, work must cease immediately.

Protocol per Surat Operations

Environmental Management Plan.

▪ Any incidents including access into cultural

heritage no-go zones or damage to any

items or areas of cultural heritage value

must be reported to the Site Supervisor

▪ Non-compliance and incident reporting

will be closed out by management to

ensure prompt rectification, as required.

10.5 Risk assessment The magnitude and severity of potential impacts has been determined based on technical

assessment carried out by suitably qualified and experienced specialists. As a result of implementing

the mitigation and management measures outlined above the likelihood rating of 1 for impacts to

heritage environmental values as there would only be circumstances of such impacts occurring

under conditions and circumstances for PL 511.

The consequence of impacts to heritage values has been determined as being minor as there would

only ever be limited damage with little or no environmental harm. Thus, risk score is based on the

likelihood and consequence rating is categorised as rare.

11. WASTE In Queensland, waste management is prescribed by the provisions of the EP Act, Environmental

Protection Regulation 2008, Waste Reduction and Recycling Act 2011 and Waste Reduction and

Recycling Regulation 2011.

The term “waste” refers to anything that is left over, or an unwanted by-product, from an industrial,

commercial, domestic or other activity, and may be either solid, liquid, or vaporous materials,

compounds or constituents that are discarded, disposed, spilled, and which may have the potential

to impact upon environmental values.

Armour will generate both general and regulated wastes throughout the well stimulation activities.

The major additional waste generated through the proposed amendment would be stimulation

flowback fluids (likely mixed with small volumes of produced water existing in the target formation).

11.1 Description of environmental values Although there are currently no prescribed environmental values for waste management, those

previously prescribed under the Environmental Protection (Waste Management) Policy 2000

(repealed) provide some guidance on the matter. The former environmental values for waste were:

▪ the life, health and wellbeing of people;

▪ soil, air, and surface and groundwater quality; and

▪ land use capability, having regard to economic considerations.

11.2 Emissions and releases

11.2.1 Exhaust emissions As previously presented, the proposed activities will generate exhaust fumes from operation of

various well stimulation equipment and the flaring of gas. Corresponding environmental

management practices for these emissions are outlined in Section 5.

11.2.2 Stimulation flowback Flowback fluid is the key waste to be generated through the proposed amendment. It will be

collected in modular pre-fabricated tanks and disposed of offsite at a suitably licensed waste

disposal facility. As discussed in section 13.1.3.4 below, a stimulation flowback monitoring program

will be implemented. This will allow for accurate characterisation of the waste to be disposed of in

order to ensure acceptance criteria will be met. Armour will also use this monitoring to assist in

determining the “cut-off” for when fluids flowing back from the well should cease being treated as

flowback for licensed disposal and instead managed as “produced water” as per 11.2.3 below. This

will be guided by the detailed risk assessment described in section 13.6.3.3 but key criteria will likely

include:

• Water quality within 10% of background as determined in accordance with section 13.1.3.1

(assuming sufficient produced water is available to undertake this sampling); or

• Water quality within 10% of background water quality in relevant evaporation dam(s); or

• Evaluation of consequence categories, design plan and operational plan of the evaporation

dams as regulated structures.

11.2.3 Produced Water Relatively conservative volumes of produced water may be generated by the proposed activities

which re-used wherever possible. Armour anticipates less than two barrels per day of produced

water however if volumes greatly exceed this volume then produced water may be diverted via a

separator to the existing licensed evaporation pond.

11.3 Likely impacts and proposed management practices Armour has considered the types of waste that will be generated by the proposed activities. These

are presented in Table 11.1 and are categorised as:

▪ general waste - those not defined as regulated waste under legislation. General wastes comprise

putrescible wastes (easily decomposed, recyclable by composting) and non-putrescible wastes

(not easily decomposed, may be recyclable);

▪ recyclable waste – this waste type is able to be reconditioned, reprocessed or reused; and

▪ regulated waste - regulated wastes are those that require specific controls or actions as defined

by legislation. Listed, hazardous, regulated, controlled or trackable wastes typically have unique

handling and disposal requirements in order to manage specific associated hazards.

Table 11-1 Waste likely to be generated and key management measures

Waste Name Description PL 511 Activity

Minimisation/ Management Measures

General Waste

Domestic wastes

▪ Food scraps, tea bags, coffee grounds etc.

▪ Food wrappers and packaging

▪ Textile materials

▪ Plastic wrapping films, plastic bags

▪ Pens and pencils

▪ Polystyrene

▪ Aluminium foil, waxed paper or cardboard

▪ Non-recyclable plastics

▪ No recyclables, hazardous wastes, liquids, chemicals or batteries.

All activities Disposal to landfill.



Timber Untreated and treated timber derived from packaging and uses that cannot be reused or recycled.

All activities

Recycled/reused where practical otherwise disposed to landfill.

Uncontaminated scrap metals and wiring

Uncontaminated scrap metals and wiring.

No pressurised cylinders or drums with chemical or oily residue.

All activities Recycled where practical otherwise disposed to landfill.

Spent stimulation fluid

Flowback fluid and excess stimulation fluid containing trace additives

Stimulation activities

Reused where practicable otherwise transported to appropriately licensed waste disposal facility

Produced water If any, will be evaporated in existing licensed ponds

Production activities

Reuse wherever possible otherwise evaporated

Recyclable Waste

General Recycling

▪ Plastic bottles and clean food containers

▪ Glass bottles and jars, milk cartons, aluminium bottles and cans, metal lids from jars, tin cans, plastic and paper cups.

▪ Cardboard and paper packaging ▪ Folders, phone books,

envelopes, office paper, magazines, cereal boxes, clean paper towels.

▪ Scrap metals (uncontaminated) ▪ No plastic food wrap or general

waste.

All activities Recycled at local facility wherever practicable.

Intermediate bulk containers

Containers used for transport of fluids and bulk materials.

All activities Returned to supplier once no longer required.

Scrap Metals

Uncontaminated scrap metals and wiring

No pressurised cylinders or drums with chemical or oily residue.

All activities Reuse, sell or return to supplier wherever practicable.

Regulated Wastes



Batteries

Lead, gel, nickel-cadmium and alkaline type batteries generated from equipment, vehicles, generators and electronics.

All activities

Transported by appropriately licensed transporter to an appropriately licensed disposal/recycling facility

Chemical waste and chemical containers (including plastic fuel, and lubricant containers)

Chemical wastes may include herbicides, pesticides, water treatment chemicals (biocides), paint and solvents. Regulated chemical containers are those containing any volume of free chemical that is regulated. These may include waste oil containers, and aerosol cans containing solvent or paint.

All activities

Contaminated soil Contaminated soils are generated where local spills of hydrocarbons and other contaminants may occur.

All activities

Oily filters, rags, absorbents

Oily filters, rags and absorbents are generated from routine equipment and vehicle servicing, repair and filter changes.

All activities

Tyres Tyres and tubes are generated from tyre changes on work vehicles and equipment.

All activities

Used spill kits Used spill kits are generated from spill clean-up of chemicals and hydrocarbons.

All activities

Waste oil (clean waste oil)

Quantities of waste oil are generated routinely from vehicle and equipment oil changes.

All activities

11.4 Risk assessment In general, waste generated for general, recyclable and regulated wastes can be appropriately

managed by the proposed management practices. The Roma Landfill has an estimated lifespan of up

to 30 years and sufficient capacity to deal with waste generated (Pacific Environment Limited, 2015),

and pest access will be negligible due to waste management and containment practices.

Additional vehicle movements associated with waste transport shall be minimised through

appropriate waste segregation and onsite reuse, wherever possible. On this basis, the likelihood of

potential l impacts to waste environmental values is rated as 1. The corresponding consequence of

impacts to waste environmental values has been determined as being minor as there would only

ever be limited damage with little or no environmental harm. As a result of implementing the

management practices outlined above, the risk of environmental harm to waste environmental

values and the surrounding environment is categorised as rare.

12. WATER

12.1 Existing environment

12.1.1 Surface water PL 511 is situated in the Condamine-Balonne Basin. Watercourses in this basin are mostly ephemeral

with the exception of major watercourses (i.e. the Condamine and Balonne Rivers). The catchment is

heavily impacted by anthropogenic pressures including land use, riparian management, water

infrastructure and point source pollution and is also highly modified as a result of agricultural and

grazing practices.

Existing surface water within PL 511 comprises of the upper reaches of the Balonne River (situated

approximately 3.47 kilometres from the proposed activities) and predominantly ephemeral Myall

Creek (250 metres from the closest well) and Wallambilla Creek (4.9 kilometres from closest well).

The semi-permanent Noorindoo Lagoon located in the north-eastern corner of the tenure

(approximately 2.5km away).

12.1.2 Groundwater The Surat Basin forms part of the GAB which is comprised of several aquifers and confining aquitards

(Figure 12-1). The main aquifers and corresponding groundwater chemistry is summarised as

follows in Table 12-1 (OGIA (2016b)):

Table 12-1 Major aquifers underlying PL 511

Aquifer OGIA (2016b) description Confined/ unconfined

Average depth Average thickness

Bungil Formation Fresh to brackish water. Mean TDS of 450 mg/L with a range of between 70 and 7500 mg/L. Mean long-term recharge rate 1.3 mm/yr. Estimated annual recharge volume 8,552 ML/yr.

confined/ unconfined

500 metres 100-200 metres

Mooga Fresh to brackish water. Mean TDS of 450 mg/L with a range of between 70 and 7500 mg/L. Mooga Sandstone is fresh to brackish and dominated by sodium bicarbonate but becomes chloride-rich in the north. Estimated mean long-term recharge rate 2.7 mm/yr. Annual recharge volume 17,003 ML/yr.

confined 700 metres 100-200 metres

Gubberamunda Sandstone

Fresh to brackish water. Mean TDS 480 to 1160 mg/L although some bores up to 5600 mg/L. Mean recharge rate 4.6 mm/yr. Annual recharge volume 14, 382 ML/yr.

confined/ unconfined


Springbok Sandstone

Fresh recharged to slightly brackish. Mean TDS 1000 mg/L (range between 200 and 7000 mg/L). Long-term mean recharge rate 1.8 mm/yr. Annual recharge volume 6,832 ML/yr

confined (in part)


Hutton Sandstone TDS range 70 to 16,000 mg/L with a mean TDS of 1,600 mg/L. Long-term average recharge estimate of 4.8 mm/yr and total annual recharge volume of 58,432 ML/yr.

confined (in part)


Precipice Sandstone

Freshwater with salinity ranges from 50 to 850 mg/L and a mean salinity of 193 mg/L. Long-term mean recharge 20.8 mm/yr. Estimated recharge volume is 53,871 ML/yr

confined 1700-1800 metres

50-100 metres

Key aquitards are the Evergreen Formation, Walloon Coal Measures, Westbourne Formation, Orallo

Formation, Wallumbilla Formation and Griman Creek Formation (Figure 12-1). Hydraulic properties

for the identified aquitards are provided in Table 12-2 below.

Table 12-2 Hydraulic properties of underlying aquitards

Aquitard OGIA (2016b) description

Evergreen Formation Major regional aquitard between the Hutton sandstone and Precipice Sandstone; dominated by low-permeability siltstone, mudstone and subordinate fine-grained labile sandstone. Average thickness 125 metres. Median horizontal permeability of 0.006 mD

Walloon Coal Measures low permeability aquitard.

Westbourne Formation Aquitard and confining bed for the Springbok Sandstone.

Orallo Formation Leaky aquitard varying in thickness from 140 to 270 metres (average 200 metres)

Wallumbilla Formation Acts as an aquitard although does have some minor discontinuous aquifers. Median permeabilities range between 0.26 to 37 mD.

Griman Creek Formation Maximum thickness of 400 metres. Median permeabilities range between 100 to 400 mD

Rewan Formation Armour’s principle target formation, and the primary aquitard between the Bandanna Formation and overlying Precipice Sandstone Surat Basin sediments. Mean permeabilities range from 0.03 to 0.33 mD.

Armour is not aware of any interactions between these formations with surface waters in or within

close proximity to PL 511.

Figure 12-1 Regional hydrostratigraphy

(Source: http://www.bioregionalassessments.gov.au/data/stratigraphy-surat-bowen-and-clarence-

moreton-basins-and-corresponding-model-layers-office)

12.1.3 Groundwater usage The primary use of water within the Surat region is for stock, the secondary use for domestic

purposes and to a lesser extent for urban water supply, agriculture (including irrigation and intensive

stock watering) and industrial purposes.

As previously discussed, the primary aquifers targeted for groundwater extraction around PL 511 are

the Mooga Sandstone and Gubberamunda Sandstone.

The Department of Natural Resources, Mines and Energy (DNRME) water bore database identifies

two water bores within PL 511:

Table 12-3 Water bores located within PL 511

Bore ID Name Depth (Metres) Formation Comment

22235 UOD Myall Creek 1 200-300* Gubbermunda Water supply bore

23216 N/A (Artesian bore – controlled flow)

200-300* Gubbermunda Water supply bore

(*Assumed based on known depth of Gubbermunda.)

UOD Myall Creek 1 is visible in Figure 12-1 and is located 571 metres from the nearest sensitive

receptor. However, recent field inspections confirmed that UOD Myall Creek 1 is actually not a water

bore but in fact a cased and suspended petroleum well (government records confirm that this

occurred in 1964) and therefore not considered a sensitive receptor. Armour will also notify DNRM

of this erroneous inclusion and recommend that UOD Myall Creek 1 is removed from the water bore

database as a matter of priority.

The unnamed water bore (ID 29579) located to the south (in PL 192) was drilled in 1946 to a depth

of 152.4 metres (see Figure 12-1) and is 1233 metres away from the closest proposed well.

Figure 12-2 Water bore proximity to proposed petroleum wells in PL 511

12.1.4 Groundwater dependent ecosystems Groundwater-dependent broadly describes a range of ecosystems that rely on groundwater for

survival. These may include wetlands, vegetation, springs, river baseflows (and cave ecosystems.

Groundwater-dependent ecosystems can be present within natural springs located in groundwater

recharge zones and in discharge zones.

There are no identified discharge or recharge springs located within the vicinity of PL 511.

12.2 Description of environmental values The Environmental Protection (Water) Policy 2009 (EPP Water) prescribes the environmental values

and water quality objectives for protection and enhancement, specifically:

▪ the aquatic ecosystems and the biodiversity functions they provide, including watercourses,

wetlands, springs and groundwater dependent ecosystems (GDEs);

▪ the suitability for stock watering;

▪ the suitability for farm supply/use;

▪ the physical and chemical attributes of surface water; and

▪ the integrity of waterways bed and banks.

Environment values for groundwater include its ability to be used for:

▪ drinking water;

▪ primary, secondary and visual recreational use;

▪ irrigation, stock watering and other agricultural uses;

▪ aquaculture use;

▪ industrial use;

▪ Cultural and spiritual values; and

▪ GDEs.

12.3 Emissions and releases The activities to be carried out in PL 511 do not involve any planned emissions or releases to surface

waters. However, there is the potential for hydraulic stimulation fluids to impact upon ground and

surface waters, specifically:

▪ during storage and prior to stimulation activities being undertaken, stimulation chemical

additives could inadvertently be spilled and impact upon nearby waterways or wetlands;

▪ stimulation fluid flowback could potentially be spilled into adjacent waterways or wetlands;

▪ losses of well integrity may cause stimulation fluids to leak into overlying or underlying aquifers

(see Section 13.4.1);

▪ fracture pathways could migrate beyond the stimulation impact zone, resulting in

interconnection of aquifers or hydraulic stimulation fluid vertically migrating into overlying and

underlying aquifers (see section 13.4.2); and

▪ remnant stimulation fluids in target formation (see section 13.4.3).

12.4 Likely impacts and proposed management practices The environmental management and mitigation measures proposed for water resources are

outlined below. A summary of the key management practices is provided in Table 12-1.

12.4.1 Appropriate chemical storage Stimulation chemicals will be stored and handled in accordance with relevant standards and

guidelines to prevent or minimise releases to the environment from spillage and inadvertent losses

during overtop and flood events.

Armour will minimise the risk of spillage by storing only the minimum volume of stimulation

additives that are necessary to complete the proposed activities onsite. Where necessary, Armour

will have chemicals delivered to PL 511 on an “as needed” basis (as opposed to stockpiling and

storage of stimulation additives).

Stormwater will be diverted around chemical storage areas to ensure that surface runoff does not

become contaminated and enter any nearby waterway.

As previously discussed, a suitable location for chemical storage shall be determined in accordance

with an appropriate constraints analysis. This would involve a review of GIS mapping layers to

identify any environmental or other constraints identified and choosing an appropriate storage

location that will avoid or minimise the impacts on environmental values wherever possible.


preferred location(s) for temporary storage.

12.4.2 Containment of stimulation fluid and flowback Post-stimulation, flowback fluid will be captured and stored within pre-fabricated tank storage

systems. Tank construction is typically solid steel framing and lined with geotextile and polyethylene

material and can be fitted with leak detection systems.

Suitable tank locations shall be determined in accordance with an appropriate constraints analysis.

This would involve a review of GIS mapping layers to identify any environmental or other constraints

identified and choosing an appropriate storage location that will avoid or minimise the impacts on

environmental values wherever possible.


preferred location(s) for tank locations.

A range of control measures may be implemented to ensure that flowback storage does not impact

on the surrounding aquatic environmental values, such as:

▪ monitoring of modular structures to ensure that the hydraulic and structural integrity is

maintained;

▪ visual inspection of structural components (, fencing, free broad, tank super-structures,

dam/tank liner integrity) to ensure containment integrity; and

▪ operating each containment system in accordance with the advice of a suitably qualified and

experienced person.

In the unlikely event that a spill or leak occurs, the spill should be contained and cleaned up as per

conditions in the EA and the Armour Site Emergency Response Plan – Surat Basin.

12.4.3 Fracture migration Refer to Section 13.4.1

12.4.4 Well construction and integrity Refer to Section 13.4.2

Table 12-4 Water - Likely impacts and key management practices


▪ Inadvertent spillage of stimulation chemicals

and impact upon nearby waterways

▪ Inadvertent spillage of flowback fluid to

waterways

▪ Losses of well integrity (see Table 13-1).

▪ Excessive fracture migration (see Table 13-

1).

▪ Residual fluid in target formation (see Table

13-1).

▪ Stimulation additives stored in accordance with relevant industry standards and legislative requirements.

▪ Where necessary, appropriate monitoring

of pre-fabricated tanks (i.e. sufficient freeboard, liner integrity, wall integrity, etc.) to avoid spillage to waterways

▪ Spills cleaned up in accordance with the

Surat Operations Environmental Management Plan and Site Emergency Response Plan - Surat Basin.

12.5 Risk assessment There are limited permanent waterbodies within PL 511. The majority of surface waters are

ephemeral in nature with flow mainly occurring in response to heavy rainfall. Potential impacts from

stimulation fluid are only likely to occur during extreme rain events causing storage tanks to

overflow, however this is extremely unlikely to occur as well site personnel will not undertake

stimulation activities where there is a risk of inclement weather. Furthermore, flowback will reused

wherever possible and so will not be stored for extended periods, thus minimising the exposure to

extreme weather events. On that basis, the likelihood rating is 1. Consequences of the associated

impacts to aquatic habitats, downstream water users and waterway bed and banks from proposed

activities would be minimal, short term, and have recoverable minor impact on water users and

biota, and the resultant consequence rating is 1.

In relation to groundwater, Armour does not consider there to be anything more than a remote

likelihood (rating 1) of hydraulic stimulation fluid leaking into the overlying aquifers. Predictive

fracture modelling indicates well stimulation fractures with a maximum lateral length of 178 metres

and maximum vertical fractures of 17 metres, and completely confined within the thick target

formation. The Rewan is also separated from the nearest overlying aquifer by hundreds of metres of

aquitard (Evergreen Formation, Walloon Coal Measures, Westbourne Formation, Orallo Formation,

Wallumbilla Formation and Griman Creek Formation). The hydraulic properties and low permeability

of these overlying aquitards indicate that it would be virtually impossible for fluid migration into

overlying groundwater resources.

Water bore (ID 29579) located to the south is located 1233 metres away from the closest well and is

drilled to a depth of 152.4 metres and is more than 1600 vertical metres from the target formation.

Furthermore, the low permeability of the target formation itself will preclude any migration of

hydraulic stimulation fluid beyond the stimulation zone. This is further compounded by the pressure

variant between stimulation fluids in the rock pore space and the petroleum well, whereby the

resultant pressure gradient causes the fluid to flow back toward the well (i.e. as opposed to vertical

or lateral migration away from the stimulation zone). Thus, the consequence for fluid migration is

assessed as being rare (rating 1).

Although from a technical perspective it is virtually impossible for the stimulation fluid to enter into

an adjacent aquifer, the consequence of this occurring and impacting groundwater quality has

nonetheless been considered. The stimulation additives that will be used will be at such low

concentrations, and of relatively benign nature in those concentrations, that the consequence of

interaction of stimulation fluid (which is predominantly water) and any groundwater resource would

be minor (rating 1). On that basis, Armour has determined the overall risk rating as 1.

The likelihood of adverse impacts to groundwater within the Rewan Formation is also determined as

being rare (rating 1). The Rewan is too deep for landholders to access without specialist petroleum

well drilling equipment and is also a widely recognised aquitard. The Rewan is also a liquid

hydrocarbon bearing formation. The small volumes of water that might be extractable would likely

contain high levels of naturally occurring liquid hydrocarbons and would be unsafe for domestic or

agricultural uses. Armour has determined that the consequence of stimulation fluids negatively

impacting upon water quality in the Rewan Formation as being minor (rating 1), and the overall risk

rating is 1.

In terms of aquifer drawdown, Armour intends to source water from the Maranoa Regional Council

and, as such, there is no anticipated aquifer drawdown and so the risk rating is 1.

Armour has determined the overall risk rating to surface water and groundwater as 1.

13. STIMULATION ACTIVITIES

13.1 Activity description

13.1.1 Stimulation program The main benefit of hydraulic fracture stimulation in an oil and gas project is to reduce the total

required number or density of drilled wells within the project area to effectively produce the optimal

amount of oil and gas from a specific reservoir. Often there are concerns with whether the fracture

is contained and how one can ensure that the fracture is not contacting aquifers. This section

addresses these concerns and issues, specifically demonstrating the design of the hydraulic fracture

simulation program that minimises the risk to as low as reasonably practical and that

interconnection of aquifers will not be caused.

Multiple fracture stages (also known as “multi stage fracs”) within a highly deviated or lateral well

increases the effective drainage area or Stimulated Reservoir Volume (SRV) as compared to a single,

vertical, hydraulically fractured well in the same reservoir. When multiple wells are drilled from a

single pad site, this further reduces the required number of drilled wells required within a project,

often by an order of magnitude. Then, when multiple wells with laterals extending radially are sited

on a single pad, the total process improves and reduces the environmental impact.

For example, the total water requirements decrease for a multi-well, multi-lateral wellsite as

compared to single well sites as the flowback water from one well can be recycled for other wells on

the same site resulting in lower losses and water management efficiencies. Therefore, Armour plans

to implement multi-well pads with multiple laterals each employing multiple sequentially staged

fracs in order to minimise its long-term footprint on the environment.

The fracture stimulation decision making process is represented in Figure 13-1.

Figure 13-1 Fracture stimulation decision making process

A well can be identified as a frac candidate based

on:

• core/DST data in the well or offset well;

• lower-permeability area based on past/current

well history; and

• damage or production underperformance.

Any known

geologic faults that could

interconnect target zone to

aquifers?

Yes

Develop alternative well strategy to

achieve higher production through

drilling and completion techniques

Adequate shale(s),

coal(s), or sufficient in-situ stress

present to provide standoff and

isolate fracture from overlying

and underlying aquifers?

No

Open hole or cased hole completion

strategy?

Can reducing the number of

interval(s) reduce the risk?No

No

Yes

Reduce the interval(s) to provide

adequate standoff or isolation from

underlying/overlying aquifers

Yes

Set intervals based

on risk assessment

Set ECP depth

based on risk

assessment

Cased Hole Open Hole

Establish cement design to isolate aquifers

from frac intervals with adequate strength

cement

Perform cement job to isolate aquifers

from frac intervals with adequate strength

cement and lead (or lower density) slurry

back to surface pipe

Results of prior diagnostics in the area

or analogue diagnostic data from

similar geologic conditions

Results of detailed geologic model and

ongoing seismic interpretation

Assess cement job with cement evaluation

log back to surface pipe

Is cement job

adequate to maintain isolation of

frac treatment?

YesIs a frac treatment still a

well objective?

Prepare well completion programme

without frac

Prepare well completion programme

including frac treatment

No

No

Perform cement squeeze job to improve

cement integrity

Yes

Well log data or data from wells with


Results of hydraulic fracture modelling

using well log data or data from wells

in similar geologic conditions

13.1.2 Stimulation fluids

Which specific fracture stimulation fluids is based additives depend on the unique properties of the

fluid designed to create the optimal fracture in a given setting. Specific stimulation additives may be

used in low concentrations and may typically include:

▪ acids (e.g., hydrochloric acid, ascorbic acid, acetic acid);

▪ bases (e.g., sodium carbonate, sodium bicarbonate, potassium carbonate, sodium hydroxide);

▪ salts (e.g., sodium chloride, potassium chloride);

▪ biocides (e.g., sodium hypochlorite, tetrakis (hydroxymethyl) phosphonium sulphate);

▪ polymers (e.g., guar gum, hydroxyl ethyl cellulose, xanthan gum);

▪ polymer stabilisers (e.g., sodium thiosulphate);

▪ polymer crosslinkers (e.g., boric acid, sodium borate, boric oxide);

▪ polymer breakers (e.g., hemicellulose enzyme breaker, sodium persulphate, ammonium persulphate, diammonium peroxidisulphate);

▪ iron control agents (e.g., ethylene diamine triacetic acid, nitrile triacetic acid, erythorbic acid; and

▪ surfactants.

The service companies performing the hydraulic stimulation campaign typically utilise the most

ecologically friendly additives available to minimise surface and sub-surface environmental impacts.

In almost all cases, the additives are commonly found in most homes and the polymers used are

common thickeners used in foods and personal hygiene products. Oxidisers and enzymes are used to

aid natural degradation, breaking down the long-chained polymers into small simple sugars that can

be flowed back with the base water to the surface at the conclusion or clean-up of the stimulation

treatment. Armour Energy will disclose all additives used by them in the hydraulic stimulation of any

well.

Proppants are used in fracture stimulation to hold open a specific portion of the fracture area within

the desired oil and gas reservoir. This provides an artificial and preferential pathway for oil and gas

production and increases the effective drainage area of the well. The proppant is comprised of fine-

meshed selectively sized silica sand and may also include stable, polymeric-coated non-toxic resin-

coated sands to improve the hardness or tackiness of the internal sand grain. In deeper wells a

higher strength, manufactured ceramic or alumina bead may be required to maintain the created

fracture width based on the depth and closing stress on the fracture. In each case, the proppant

selected is designed to create a targeted, stimulated reservoir volume to enhance the extraction of

oil and gas from the well.

Chemical composition and environmental persistence of each stimulation additive will be considered

once each fracture event has been allocated to a service provider and detailed plans developed.

13.1.3 Stimulation monitoring

13.1.3.1 Pre-stimulation groundwater monitoring If any associated water is produced from the target hydrocarbon-producing formation while drilling,

it will be water quality tested. This will enable a more accurate prediction of any possible

contaminant concentrations in the post-stimulation flowback water. The parameters that will be

tested will be in accordance with the stimulation management procedures developed under the

proposed conditions.

Armour will undertake water quality monitoring of landholders’ active groundwater bores within a

2km radius of the proposed stimulation activities, regardless of the target hydrocarbon producing

formation’s proximity to the landholder’s bore source formation.

13.1.3.2 Onsite Stimulation Design Assurance Monitoring Program During the fracture stimulation treatment it is important to assure that the ongoing treatment is

progressing as designed and that the design parameters used in accordance with the pre-stimulation

stimulation risk assessments, an onsite diagnostics program will be implemented to assure that the

treatment is progressing as per design.

For example, treating pressures are the primary diagnostic to assess whether the actual job is

performing relative to design as the pressures to propagate the fracture are related to the in situ

stress environment in the reservoir being stimulated. An onsite pressure diagnostic decision tree

(Figure 13-2) will be employed during the stimulation treatment to assure that the actual job is

progressing as per design criteria.

If a variance between the design and actual occurs, the Armour onsite engineer will contact the

office with the onsite information. There, any identified risks can be assessed in accordance with

Armour’s Risk Assessment Matrix. Finally, after the stimulation, zonal isolation will be assessed

through post-fracture production history-matching, pressure monitoring and flowback stimulation

fluid testing.

Figure 13-2: Onsite Pressure Diagnostic Decision Tree

A well is a frac candidate based on a:

• well programme has been developed including a

frac job;

• frac model has been developed to match against

observed pressures onsite; and

• programme and additives have been submitted and

approved by regulatory groups.

Were additional intervals

chosen to provide standoff and

isolate fracture from overlying and

underlying aquifers?

Are observed pressures

conformable to the pre-frac modelled

pressures?

Yes

Perform pre-frac injection test with

treated water (pH control, bactericide

only) on uppermost and lowermost

intervals of interest

No

Proceed with main frac treatment

Run temperature survey to ascertain

observed frac height, review with Armour

Technical Team

Yes

No

Results of prior diagnostics in the area

or analogue diagnostic data from


Results of detailed geologic model and

ongoing seismic interpretation

Submit all required post frac data,

reports, and chemical usage to

regulatory authorities

Well log data from or data from wells

with similar geologic conditions

Results of hydraulic fracture modelling

using well log data or data from wells

in similar geologic conditions

Identify them on log and assure frac

model coverage and understanding of

stress values between the target

intervals and the aquifer(s)

Is isolation maintained?

Yes

No

Yes

Do not proceed with frac treatment on the

interval

Proceed with regulatory agency

notification processes, evaluate

production/salinity from the interval,

remediate if required

Do observed pressures

conform to the pre-frac modelled

pressures?

Run temperature survey to ascertain frac

height

No

Is there

containment to the desired frac

intervals to assure aquifer

isolation?

No Yes

Adjust model to observations and assure

isolation is maintained with main treatment

design

Was treatment isolation

breached as indicated by the

temperature survey?

Yes

No

Confer with Armour Technical Team

13.1.3.4 Post-Stimulation Flowback Monitoring Program

Due to the fact that there is no environmental values of the target formation, the key purpose of

flowback monitoring is to ensure the flowback is properly characterised prior to disposal. As such,

the post-stimulation flowback monitoring program will ensure compliance with the requirements of

the proposed condition for stimulation management procedures and involves:

• full analysis of the fluid for all stimulation additives

• analysis of key parameters that may be present in the target formation:

o metals

o hydrocarbons

The monitoring will be undertaken within one week of flowback ceasing.

13.1.3.5 Post-Stimulation Groundwater Monitoring Armour will undertake post-stimulation water quality monitoring of landholders’ active groundwater

bores within a 2km radius of the proposed stimulation activities, regardless of the target

hydrocarbon producing formation’s proximity to the landholder’s bore source formation.

13.2 Existing environment Refer to Section 6.1.2 for geological setting, and Section 12.1 for hydrogeological setting.

13.3 Description of environmental values There are no prescribed environmental values relating to well stimulation activities for PL 511.

However, based on the assessment of the existing environment, the environmental values to be

protected or enhanced (in relation to stimulation activities) are:

▪ the integrity of underlying and overlying aquifers adjacent to the target formations; and

▪ the physical and chemical attributes of groundwater.

13.4 Emissions and releases Stimulation fluid (approximately 96% water, 3.5% or more of ceramic proppant and 0.5% or less of

trace additives) will be pumped into the target formation, with at least 60% of the fluid expected to

return to the surface in these conventional tight gas sandstone reservoirs.

13.5 Likely impacts and proposed management practices There is the potential for hydraulic stimulation fluids to impact upon the surrounding environment,

specifically:

▪ losses of well integrity may cause stimulation fluids to leak into overlying or underlying aquifers;

▪ although highly unlikely due to the vertical separation fracture pathways could migrate beyond

the stimulation impact zone, resulting in interconnection of aquifers or hydraulic stimulation

fluid vertically migrating into overlying and underlying aquifers;

▪ surface exposure to chemicals; and

▪ remnant stimulation fluid in formation.

13.5.1 Well construction and integrity Well construction shall be undertaken in accordance with the industry document, “Code of Practice

For the construction and abandonment of petroleum wells and associated bores in Queensland” and

Armour’s Well Integrity Management Plan (attached.

The casing programme will consist of 9 5/8-inch casing set below the Bungil Formation, followed by

7-inch casing to just above the Rewan Formation and 4 ½ inch casing cemented across the Rewan

Formation to a total depth. This design will seal off water flows from the Bungil Formation to reduce

the risk of cross-flows between aquifers and the uncontrolled release of well bore fluids to surface,

throughout the life of the well.

All casing and tubing has been manufactured to strict standards and complies with the latest edition

of ISO 11960, and shall be set at appropriate depths to provide an adequate safety margin between

the formation fracture pressure and anticipated pressures during well control and casing

cementation operations.

Well casing specifications (10,000psi) significantly exceed the proposed hydraulic stimulation surface

pressures in order to maintain well integrity. Critical casing loads and safety factors have been

calculated for each casing string, utilising specialised well analysis software and real-time monitoring

undertaken of pressure and temperature effects during the proposed activities.

Purpose-designed cement and installation techniques shall be used address geologically-specific

conditions for each petroleum well to provide a robust seal that isolates the well from the

surrounding formations and protects the well materials from extreme formation conditions.

Appropriate cement laboratory testing procedures shall be carried out on representative samples of

the mix water, cement and additives to confirm the resulting primary cement slurry meets the

requirements of the well design.

13.5.2 Fracture migration In standard coal seam gas activities, excessive fracture migration has the potential to create

connectivity between target formations and adjacent aquifers and, in turn, impact upon the

environmental values of the groundwater in those aquifers. However, for this project targeting much

deeper hydrocarbon target formations, there are very large separation distances from aquifers used

for water resources. This effectively means the chance of migration from the target formation to

aquifers is remote as detailed further below.

The specific design of hydraulic stimulation operations for PL 511 will ensure that the risk of

fracturing beyond the boundaries of the target formation is minimized to the greatest extent

practicable, and that the hydraulic stimulation fluid should remain contained within the target

formation and the well bore.

The target Rewan Formation in PL 511 is 200-800 metres thick and more than 1800 metres below

the earth’s surface, whereas landholder-targeted aquifers in the region are typically no more than

300 to 500 metres deep (Bungil, and possibly Mooga Formations). There is a single landholder bore

within PL 511 which is located in the Gubbermunda Formation (i.e. depth of 200-300 metres).

Fracture modelling (taking into account the individual properties of the petroleum well, target

formation, stimulation fluid, etc.) predicts a fracture height (i.e. vertical) and flowing fracture length

(i.e. horizontal) of up to 17 and 178 metres, respectively.

This means that there will be at least a thousand metres of impervious rock between the hydraulic

fractures and any other aquifer. The likelihood therefore of a hydraulic fracture penetrating an

overlying or underlying aquifer is extremely low. Furthermore, all stimulation activities will be

conducted at depths below the Snake Creek Mudstone Member which acts as a geological seal

therein preventing fluid migration and cross-flow between adjacent aquifers.

Fracture migration may be monitored using radioactive tracers (as an additive to the stimulation

fluid).

13.5.3 Remnant fluid in formation As previously discussed, approximately 60% of the stimulation fluid is expected to pumped to the

surface as flowback following each stimulation treatment. Over time, a further 20% may be

“produced” from the well (commingled with gas, hydrocarbon liquids and small volumes of

produced water) (total 80% recovery).

Table 13-1 Stimulation Activities - Likely impacts and key management practices


▪ Loss of well integrity causing loss of

stimulation fluids into overlying or

underlying aquifer

▪ Fracture pathways could migrate beyond the

stimulation impact zone, resulting in

hydraulic stimulation fluid vertically

migrating into overlying and underlying

aquifers.

▪ Remnant fluid in formation

▪ Appropriate well design and construction

provide the mechanical integrity of the

well bore for the operational conditions

and life of the well.

▪ Wells designed and constructed in

accordance with Armour’s Well Integrity

Management Plan.

▪ Casing design modelled in accordance

with appropriate industry standards and

engineering specifications

▪ Critical casing loads and safety factors

have been calculated for each casing

string, utilising specialised well analysis

software. Realtime logging services will

provide advanced surveillance to confirm

pressure and temperature effects during

the hydraulic stimulation activities.

▪ Appropriate design and engineering of

stimulation program to ensure that

fracture migration is confined to target

formation(s).

▪ Stimulation of formations beneath the

Snake Creek Mudstone Member which

acts as a geological seal and prevents

cross-flow, and fracture and fluid

migration

▪ Chemical composition and environmental

persistence of stimulation additives

managed per risks identified in the


Assessment.

13.6 Risk assessment framework

13.6.1 Overarching risk assessment An overarching risk assessment has been prepared to support this application through highlighting

key areas of concern and management strategies to be applied across the project. A summary of the

findings of this risk assessment is provided in Table 13-2.

A more detailed risk assessment will be undertaken based on specific chemicals to be used once

each fracture event has been allocated to a service provider and detailed plans developed. This risk

assessment will populate the Stimulation Management Procedures for the specific well and ensure

compliance with the proposed conditions of the EA. The specific objectives of this assessment will be

to:

1. To assess the toxicological and ecotoxicological information of chemicals

2. Provide information on the persistence and bioaccumulation potential of the chemicals used

3. Identify the stimulation fluid chemicals of potential concern derived from the risk assessment

4. Undertake an environmental hazard assessment of leaving chemicals used in the stimulation

fluids in the target gas producing formation for extended periods subsequent to stimulation

5. Assess the human health exposure pathways to Armours personnel and the regional

population; and

6. Develop the site-specific risk characterisation of environmental impacts based on the

environmental hazard assessment scope of work.

13.6.2 Chemical risk management procedures While specific risk control measures will be fully determined based on the results of the detailed

environmental risk assessment, Armour Energy provides the following commitments to good

management practices in the management of the hydraulic fracture stimulation chemicals:

1. Handling and storage of all chemicals will be undertaken in accordance with relevant

standards for health and safety, transport, storage, handling, use and disposal.

2. Liquid chemicals will be transported in approved chemical tote tanks with a catchment tray as

required by dangerous good regulations.

3. Dry chemicals will be carried in in compliance with dangerous goods regulations where

relevant and in a manner that will protect against accidental discharge, such as in bulk on

pallets.

4. Pumps, pipes and mixers will be designed ensuring they are of more than adequate capacity

and be leak tested prior to use.

5. Biocides and surfactants will be contained in sealed plastic containers that dissolve in water,

therefore requiring no human contact to add them to the stimulation fluid mix. Operators

will be trained in the handling and storage of biocides and surfactants.

6. The following chemicals will not be used in stimulation: naphthalene, phenanthrenes,

benzene, fluorenes, ethylene glycol, toluene, ethylbenzene, xylene, phenol, ethylene, diesel,

kerosene, aromatic solvents, formaldehyde.

7. A monitoring programme will be implemented, including testing of stimulation pond water

after stimulation. Stimulation pond water will not be directed to any other non- stimulation

pond or to the treatment system until test results show that it is acceptable in quality.

8. Flowback will be stored in tanks

13.6.3 Specific risks

13.6.3.1 Fracture migration Well stimulation pressures will be significantly less than actual well design specifications, thus

preventing well casing failure during stimulation activities. Real-time logging services will monitor

ongoing pressure and temperature effects during the hydraulic stimulation activities.

The likelihood of hydraulic fractures penetrating an aquifer is rated at 1 because of vast separation

between the hydraulic fracture zones and any aquifers. Fracture modelling predicts a maximum

fracture height (i.e. vertical) of 17 metres and flowing fracture length (i.e. horizontal) of up to 178

metres. The fracture would need to travel hundreds of metres within the formation to impact

adjacent aquifers and this is not physically possible with the proposed pressures and geophysical

properties of the formation. The closest water bore (ID 29579) is 1233 lateral metres away and is

drilled to a depth of 152.4 metres (i.e. more than 1600 vertical metres from the target formation).

Furthermore, the Snake Creek Mudstone Member will act as a geological seal that will prevent any

fluid migration into, or cross-flow between, adjacent aquifers. The consequence rating is assessed as

being 1 (minor) as even if the fracture did migrate far enough to join up with an adjacent aquifer

(and it is emphasised that this is not physically possible under the proposed stimulation pressures

and geophysical properties of the formation) the volume of fluid that could migrate that distance is

so the consequences of this occurring are of little or no significance in terms of environmental

impact. On that basis, Armour has determined the overall risk rating as 1.

13.6.3.2 Rewan water quality As previously discussed, there will be some residual stimulation fluid that remains within the target

formation following stimulation activities and flowback although the actual volume remaining from

the proposed three megalitre fluid volume would be less than 600,000 litres. The low concentrations

and relatively benign nature of the chemical additives used in the stimulation fluid would result in

limited impact to groundwater quality (particularly because the target Rewan Formation is a liquid

hydrocarbon bearing formation, and water that might be extracted would already be unsafe for

domestic or agricultural uses). Armour has determined that the consequence of stimulation fluids

negatively impacting upon water quality in the Rewan Formation as being minor (rating 1), and the

overall risk rating is 1.

13.6.3.3 Chemical exposure Raw, or undiluted chemicals have a variety of hazards that may result in adverse health and

environmental effects. Because of the nature of the activity, only short-term health hazards are

considered relevant. All raw/undiluted chemicals should be considered (for the purpose of diligence)

hazardous to the environment (soil and water) if they are spilled and therefore the correct handling

of the chemicals should be a priority.

Mixed or diluted chemicals are considered to be potential irritants to the skin and eyes and may

cause gastrointestinal irritation if swallowed. Due to the salinity of the mixed fluid and the flowback

fluid, it is considered to be toxic to aquatic and soil environments.

Table 13-2 Chemical Exposure Hazard Assessment Summary

Hazard Mitigation

Hazard from raw undiluted chemicals as delivered

• Short Term health hazards for exposure to concentrated chemicals as they are delivered to the site are considered to be the most relevant risk.

• Undiluted chemicals may be harmful to humans in their solid or liquid form.

• All liquid chemical should be treated as hazardous to the environment if spilt directly into a water body.

• Guar-gum (powder) may also be hazardous if spilt directly into surface water, however, guar-gum is a natural and easily biodegradable substance. The Cause of harm would be via oxygen depletion.

• All chemicals are to be transported to the site in accordance with the relevant hazardous substance regulation; and

• handled on site in accordance with the Material Safety Data Sheet (MSDS) for the product.

Hazard from mixed stimulation fluids and flowback fluids

• The chemicals are diluted and mixed as a part forming the stimulation fluid and therefore have different hazardous properties than the raw chemicals

• based on the dilution ratio of the chemicals, the likely hazard associated with the diluted chemicals would likely to extend as far as mild irritations to gastrointestinal effects.

• Fluids are considered likely to be toxic to aquatic environment and to soil organisms due to the elevated salinity. This is a low risk as the wells sites are required to be at least 100m from a watercourse.

• Fluids are expected to be of low toxicity to stock, however the water would still not be considered suitable for stock watering purposes.

• The chemicals that are present in the stimulation fluid are in lower concentrations than the undiluted product and are therefore have a lower hazard and health risk.

• Ensure that the stimulation fluids is appropriately stored on site in lined ponds or storage vessel to avoid uncontained spills to soil.

• Ensure that the fracture stimulation ponds are maintained behind a secure stock proof fence.

• Ensure that a suitably certified, or regulated waste contractor is engaged for the removal of the flowback fluid from the ponds

Findings of the exposure assessment component of the overarching risk assessment are as follows:

• Considering well integrity control measures and geological separation (discussed in There are no reasonable or plausible exposure pathways arising via the sub-surface.

• Exposure pathways for raw chemicals are limited to the spillage scenarios. In the absence of a spill, there is no pathway for to any receptor.

• The only exposure pathway to chemicals into the environment is from the management of the flowback fluid.

• The only exposure pathway to humans under normal operating conditions is to Armour staff and not the general public, due to the isolation of the drilling operation.

• Accidental releases of flowback fluid could result in serious damage to the local soils and

potential result in isolated near surface groundwater contamination. This would only be in the case of a major spill – for example a major containment failure. Any storage structures will be appropriately designed to relevant standards and accepted engineering practice and maintained with enough freeboard to avoid overtopping. Due to the very minor contributions of formation water to flowback, amount of flowback can be accurately quantified to assist in accurate fluid storage planning taking account of potential rainfall events.

Armour has determined that the consequence of stimulation fluids or flowback being released in

their diluted states with mentioned controls in place as being minor (rating 1), and the overall risk

rating is 1.

13.6.4 Ongoing Groundwater Risk Assessment Strategy As development plans for PL511 are further developed, site specific risks in relation to stimulation

will be reassessed and “stimulation management procedures” further developed and refined to

ensure full compliance with the proposed conditions. Should stimulation be sought in exceedance of

the proposed five wells or in situations where the 2km lateral or 200m horizontal separation from

landowners’ water bores is unachievable, a further amendment to the EA will be sought and

accompanied by an updated risk assessment.

14. REHABILITATION

14.1 Decommissioning infrastructure Decommissioning well stimulation infrastructure will be undertaken in accordance with the relevant

provisions of the Petroleum and Gas (Production and Safety) Act 2004, the Petroleum and Gas

(Production and Safety) Regulation 2008 and the EA.

Rehabilitation of disturbed areas shall take place progressively as works are staged and new areas

are disturbed.

14.2 Transitional rehabilitation Transitional rehabilitation will ideally be undertaken on disturbed areas associated with stimulation

activities where part of the area is no longer required for those activities.

Transitional rehabilitation aims to stabilise disturbed land prior to undertaking final rehabilitation,

thereby minimising potential impacts on surrounding environmental values (e.g. minimising erosion

and potential for weed establishment). Transitional rehabilitation involves re-contouring the land

surface if required, replacing topsoil, and direct seeding of groundcover species (pasture or native

grasses depending on the final post-disturbance land use), with ongoing maintenance required to

meet the criteria specified in the EA.

14.3 Final rehabilitation Final rehabilitation will be undertaken once the site is no longer required for operational activities.

Final rehabilitation can involve remediating any contamination, re-contouring of the landform,

replacing subsoil and topsoil, ripping as required, and revegetation with appropriate species

depending on the final post-disturbance land use.

14.4 Pre-fabricated tanks Pre-fabricated structures for storing hydraulic stimulation fluid and flowback fluids will be utilised

during well stimulation activities.

All remaining flowback fluid should be removed and transported to an appropriate treatment/

disposal facility. As with all waste, Armour shall deal with the remnant water or flowback fluid in

accordance with the waste management hierarchy (per the Environmental Protection (Waste

Management) Policy 2000) and investigate possible re-use as per requirements of the relevant EA.

Synthetic liners (if used) shall be removed and possible recycling options explored. Where recycling

is not an option, the liners shall be disposed of to landfill.

Associated pipework, pumps, water treatment systems, etc… should be decommissioned and

removed from site unless the landowner indicates that they would prefer that the infrastructure

remains in place for their use.

Where necessary, earthworks shall be undertaken to restore the location of the pre-fabricated tank

so that the resultant landform is geo-technically and geo-chemically stable (with due consideration

given to settlement, consolidation allowances, bearing capacity, erosion resistance). Compacted

surfaces beneath the tank shall be ripped, if necessary. Topsoil shall be reinstated to a depth of

250mm, followed by re-vegetation.

14.5 Road and access tracks Roads and access tracks are an integral part of the environmental management of any petroleum

project. Roads and access tracks consolidate the trafficable areas into a discrete section of each

project and avoids unnecessary disturbance to the remaining portion of each petroleum authority.

Roads and access tracks that have no further use should be decommissioned by ripping to remove

compaction, re-spreading stockpiled topsoil, and revegetation.

14.6 Water crossings Waterway crossings should be rehabilitated by re-contouring disturbed areas to match the

surrounding land as soon as practicable after petroleum activities have ceased. The surface will

usually be lightly scarified before spreading the topsoil, to promote vegetation re-growth and

protect against the topsoil loss. Temporary waterway barriers should be removed and reseeding

should be undertaken to minimise erosion and promote regeneration of riparian vegetation.

14.7 Flare pits Flare pits should generally be decommissioned within 12 months of no longer being required.

As with other containment systems, flare pits should have all remaining liquids removed and

transported to an appropriate treatment/ disposal facility or, where appropriate, reused in

accordance with the waste management hierarchy and the requirements of the relevant EA.

Synthetic liners (if used) should be removed and disposed of to landfill. Associated pipework,

pumps, water treatment systems, etc… should be decommissioned and removed from site unless

the landowner indicates that they would prefer that the infrastructure remains in place for their use.

Because of the nature and purpose of flare pits, investigations should be undertaken by a suitably

qualified person to determine the presence or absence of soil contamination.

In all circumstances, soil investigations should be conducted in accordance with the National

Environment Protection (Assessment of Site Contamination) Measure 1999 and, where necessary,

should be remediated following the Australian and New Zealand Guidelines for the Assessment and

Management of Contaminated Sites.

Backfilling should be undertaken in a manner that is complimentary to the natural contours of the

existing landscape to ensure surface subsidence is avoided. In circumstances where backfilling is not

practical, contours should be ripped and returned to a state similar to the surrounding environment.

For gibber, erosion can be minimised by maintaining batter slopes of less than 2%. Seeding or

revegetation should also be undertaken (subject to original state/distribution of vegetation).

14.8 Dust emissions during rehabilitation Dust emissions may occur at any point where soil, fill, earthen material or similar are removed,

disturbed, traversed or exposed to windy conditions during rehabilitation.

Every reasonable effort shall be made to mitigate the impact of dust emissions in accordance with

relevant industry standards and government guidelines. Such measures may include (and will

depend on the circumstances):

▪ dust suppression with water trucks or similar equipment;

▪ where practicable, seal surface roads and hardstand areas;

▪ covered loads on vehicles;

▪ mulching, vegetating and progressive rehabilitation of disturbed areas;

▪ appropriate scheduling of activities to avoid dust generation;

▪ effective planning to ensure that dust generating activities are down-wind of sensitive receptors;

and

▪ minimising dust-generating activities during periods of high wind where there is the potential to

impact upon dust-sensitive receptors.

Dust mitigation measures shall be undertaken as a routine measure and as part of Armour’s

commitment to providing a safe workplace. Additionally, dust monitoring shall be undertaken in

response to any genuine dust-related complaints received from nearby sensitive receptors, or a

direction from EHP to investigate an alleged complaint.

14.9 Noise emissions during rehabilitation Noise emissions from rehabilitation activities can have a considerable impact upon the surrounding

environment and sensitive receptors. Excessive noise emissions may have deleterious effects on

sleep behaviour, social impacts and may infringe upon an individual’s common law rights to quiet

and peaceful enjoyment of their property.

As with all potential nuisance emissions, Armour shall adopt a hierarchal approach to noise source

management, and every reasonable effort shall be made to prevent or avoid noise impacts upon

sensitive receptors.

Noise emissions shall be measured in accordance with the EHP Noise Measurement Manual and the

most recent version of AS1055 Acoustics – Description and measurement of environmental noise.

14.10 Light nuisance during rehabilitation Nuisance light emissions are those that cause an unreasonable interference with an individual’s

quiet enjoyment of their property. Light nuisance may also impact upon an individual’s sleep pattern

and therefore have deleterious social impacts.

All work lighting that is utilised during the rehabilitation process should be installed and positioned

in a manner that does not create a light nuisance to adjacent properties. Outdoor lights that must

not be angled onto adjoining properties and shall comply with the requirements of Australian

Standard 4282 – Control of the obtrusive effects of outdoor lighting.

14.11 Visual amenity of rehabilitated areas Visual aspects of rehabilitated areas can have a considerable impact upon the amenity of

surrounding sensitive receptors. Armour should undertake a review of the Planning Scheme of the

relevant local government to ensure that its petroleum activities will not adversely impact on visual

amenity of current or future sensitive receptors, such as residential dwellings and other industrial

activities.

Armour shall consider the following impact mitigation measures:

▪ where possible, obscure rehabilitated areas with native vegetation or natural landforms; and

▪ for infrastructure that is authorised to remain intact, utilising neutral colour schemes to facilitate

better integration into the surrounding landscape.

Where complaints have been received in relation to visual amenity, Armour shall endeavour to

address the issue in an expeditious and cost-effective manner.

14.12 Rehabilitation success Rehabilitation can be considered successful when the site can be managed for its designated land-

use (either similar to that of surrounding undisturbed areas or as otherwise agreed in a written

document with the landowner/holder and administering authority) without any greater

management input than for other land in the area being used for a similar purpose and there is

evidence that the rehabilitation has been successful for at least three (3) years.

Environmental indicators should be identified in order to effectively demonstrate rehabilitation

success. This may involve the measurement of a single parameter or they may involve the

amalgamation of measurements of several parameters into an index or model. There could be

several indicators for one objective and one indicator may have relevance to more than one

objective. Some may be important over a wide area while others may have a local significance or

relate to how a particular objective is to be achieved for a particular mine. The general consensus is

that a good and useful environmental indicator shall:

▪ have an agreed, scientifically sound meaning;

▪ represent an environmental aspect of importance to society;

▪ tell us something important and its meaning is readily understood;

▪ have a practical measurement process;

▪ help focus information to answer important questions; and

▪ assist decision making by being effective and cost-efficient.

Wherever possible, site-specific environmental indicators should be determined prior to the

commencement of rehabilitation works. However, in the absence of site-specific indicators, the

following generic indicators shall be applicable:

▪ final land use takes into account local and regional initiatives;

▪ land usage options obtain optimal economic and social return whilst minimising environmental

impact;

▪ final land use is compatible with surrounding land function/usage requirements;

▪ final land use addresses the limitations of land capability and growing media;

▪ land use will be aligned to the relevant land zonings and regional Planning Schemes;

▪ weeds and pest animal species (distribution and impact) are broadly comparable to baseline or

reference site;

▪ areas of bare ground are broadly comparable to reference site;

▪ live species, healthy species, trees with dieback, dead species, and species flowering is

comparable to reference sites; and

▪ growth of trees, shrubs, grasses, etc… is comparable to reference sites with consideration of

variable factors between reference and rehabilitation sites.

Rehabilitation shall be considered successful where the designated environmental indicators have

been achieved for the stipulated monitoring period.

14.13 Rehabilitation monitoring and reporting Ideally, rehabilitation monitoring should make critical comparisons with environmental monitoring

results against rehabilitation objectives, and target and identify possible trends and areas for

improvement. Monitoring shall be structured to assess effectiveness of environmental controls

implemented and, where necessary, identify modifications required for the monitoring program,

rehabilitation practices or areas requiring research.

Reporting shall be undertaken in accordance with statutory requirements.

REFERENCES

APPEA, https://www.appea.com.au/wp-content/uploads/2016/03/16-03-Ref-Doc_Onshore-

Emissions.pdf. Accessed 10 February 2018.

DATSIP, https://culturalheritage.datsip.qld.gov.au/achris/public/application-for-advice/enter.

Accessed 10 February 2018.

GAB ROP, 2007 – Great Artesian Basin Water Resource Operations Plan – February 2007.

Queensland Government

Scott S. et al (2004). Revised geology and coal seam gas characteristics of the Wallon Subgroup –

Surat Basin, Queensland. Proceedings PESA Eastern Australasian Basins Symposium II, Adelaide, 19-

22 September, 2004.

Pacific Environment Limited (2015) Waste Management Strategy – Maranoa Regional Council.

Available at:

http://www.maranoa.qld.gov.au/documents/4292453/41877895/Waste%20Management%20Strate

gy%20-%20Draft%20-%20June%202015.pdf. Accessed: 15 February 2018.

Queensland Government (2012), Environmental Protection (Noise) Policy 2008, viewed 12 February

2018, <https://www.legislation.qld.gov.au/LEGISLTN/CURRENT/E/EnvProtNoPo08.pdf>.

Queensland Government (2016a), Environmental Protection Act 1994, viewed 12 February 2018,

<https://www.legislation.qld.gov.au/LEGISLTN/CURRENT/E/EnvProtA94.pdf>.

Queensland Government (2016c), Environmental Protection (Air) Policy 2008, viewed 12 February

2018, <https://www.legislation.qld.gov.au/LEGISLTN/CURRENT/E/EnvProtAirPo08.pdf>.

Queensland Government (2016d), Environmental Protection (Water) Policy 2009, viewed 12

February 2018, <https://www.legislation.qld.gov.au/LEGISLTN/CURRENT/E/EnvProWateP09.pdf>.

Queensland Government (2017a), Environmental Protection Regulation 2008, viewed 10 February

2018, <https://www.legislation.qld.gov.au/LEGISLTN/CURRENT/E/EnvProtR08.pdf>.

Queensland Government (2017d), Waste Reduction and Recycling Act 2011, viewed 10 February

2018 https://www.legislation.qld.gov.au/LEGISLTN/CURRENT/W/WasteRedRecA11.pdf.

Santos (2014), Santos Gas Field Development Project – Environmental Impact Statement (EIS),

Chapter 17: Noise and Vibration, Queensland Development of State Development, Brisbane, viewed

12 February 2018, <http://www.statedevelopment.qld.gov.au/assessments-and-approvals/santos-

glng-environmental-impact-statements.html>.

Sattler, PS. & Williams, RD (1999), The Conservation Status of Queensland’s Bioregional Ecosystems,

Queensland. Environmental Protection Agency, Brisbane.

Savery and Associates (2009), Australia Pacific LNG Project (Document No. S851.2, Revision 1),

Volume 5: Attachment 32 – Noise and Vibration Impact Study – Gas Fields, Savery and Associates,

Brisbane, viewed 19 February 2018,

<https://www.aplng.com.au/content/dam/aplng/compliance/eis/Volume_5/Vol5_Att32_NoiseVibra

tionImpactStudy.pdf>.

https://www.appea.com.au/wp-content/uploads/2016/03/16-03-Ref-Doc_Onshore-Emissions.pdf

https://www.appea.com.au/wp-content/uploads/2016/03/16-03-Ref-Doc_Onshore-Emissions.pdf

https://culturalheritage.datsip.qld.gov.au/achris/public/application-for-advice/enter

http://www.maranoa.qld.gov.au/documents/4292453/41877895/Waste%20Management%20Strategy%20-%20Draft%20-%20June%202015.pdf

http://www.maranoa.qld.gov.au/documents/4292453/41877895/Waste%20Management%20Strategy%20-%20Draft%20-%20June%202015.pdf

https://www.legislation.qld.gov.au/LEGISLTN/CURRENT/W/WasteRedRecA11.pdf

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