May 2020: Waitsia stage 2: make a comment to the EPA

Make a comment/submission: Waitsia Gas Project

The EPA is seeking public feedback on Mitsui/AWE Perth Pty Ltd’s plans for the Waitsia Gas Project. The project is for the production of the Waitsia gasfield through 6 new gas wells, a new gas processing plant, waste water reinjection and flowlines/pipelines amongst farmland just 16km from Dongara-Port Denison townsites in WA’s Mid West. We’ve made a short guide to help you make a submission.

Comments must be lodged by Thursday 7 May 2020.

You can do that online here:

https://consultation.epa.wa.gov.au/open-for-submissions/waitsia-gas-stage-2-additional-info/consultation/intro/

Mention if you're a local!

Here are some things you might want to raise in your submission:

Water usage and quality

Mitsui/AWE has conservatively estimated that 1.2 million litres of water is to be used during the total lifespan of the gas processing plant (20 years). This water will be taken from underground aquifers, and they have conservatively estimated that the water level in the Yarragadee aquifer in the vicinity of Ejarno Spring will drop 19cm in 5 years due to this. The project may also cause changes to the groundwater and surface water quality.

You might want to ask the EPA:

  • do the water use estimates take into account the water use for the drilling of planned and future wells?
  • how does the EPA propose to maintain the hydraulic regime and quality of the Yarragadee aquifer and other groundwater and surface water in the vicinity of the proposal, and protect their environmental values?

Future fracking

In the past, Mitsui/AWE has told its investors that there is “significant potential beyond Stage 2”.1 It was referring to the additional 234 billion cubic feet of gas it can potentially extract from the tight sands fields that would require fracking. Once the pipelines and other infrastructure are in place there will be nothing stopping the proponent from trying to develop the fracking side of their business plan.

If fracking goes ahead in future, many more wells are likely to be drilled. This would mean estimates made in the various supporting documents about water usage, wastewater reinjection and emissions would be far from accurate. There are also various environmental risks associated with fracking that have not been addressed in the current assessment process.

You might want to ask the EPA:

  • Will the EPA provide assurances that fracking will not be allowed as part of this proposal, at this site and across this region into the future?

For example, the EPA could recommend conditions be imposed on the project that expressly prohibit the use of fracking.

At the very least, you could ask the EPA to recommend conditions that require a fresh environmental assessment and approval to be obtained before fracking activities are potentially allowed at the site.

[1] https://www.irmau.com/site/PDF/2614_1/AWE39sWaitsiaSiteTourPresentation

Reinjection of wastewater risks

Mitsui/AWE estimate that they will inject ~1 million cubic metres of wastewater (collected during gas production from the gas processing plant) into 3 old nearby petroleum wells, over the expected 20-year life of this project. We need more clarity from the EPA on the volume of water that will be injected. 

  • Is this just for the wastewater from the gas plant and the 8 wells mentioned in the proposal or is there likely to be more wastewater to deal with if/when more gas wells are drilled in further stages?
  • Why are back up wastewater evaporations ponds necessary, and what was the company’s assessment process to reach that conclusion?

The Water Management Plan does not appear to have done any modelling on what this wastewater reinjection proposal would mean for underground water aquifers, or the risks associated with reinjection, for example contamination of groundwater.

We are concerned as there is a direct correlation reported between deep well reinjection and felt seismic activity.2 Most recently, the US Geological Survey reported that reinjection of wastewater into depleted conventional reservoir wells (Class II aquifers) is the primary cause of the recent increase in low intensity earthquakes in certain areas of the central US.3

You might want to ask the EPA:

  • How will the EPA regulate this reinjection scheme to ensure that the hydrological regime and quality of the groundwater is maintained and environmental values are protected?
  • Will pollution impacts be made public?
  • Will the EPA provide the detail of other sites that used reinjection and what monitoring is happening?

[2] ACOLA Report; US EPA 2016a; Costa et al. 2017; USGS 2017.

[3] US Geological Survey 2017

Flaring – pollution, light and noise impacts

The nearby Irwin community has already seen, heard and felt the noise, light and pollution impacts from flaring in recent years during the exploration phase of the Waitsia proposal. With Waitsia Stage 2, there will be more well sites encroaching on the community.

Mitsui/AWE’s Management of Flaring Plan only addresses the impacts of flaring from the gas processing plant, not from the existing and planned wells to be drilled, some of which are much closer to Irwin townsite and other farms than the Gas Plant itself.

You might want to ask the EPA:

  • Will the EPA obtain more information about the impacts of flaring from the existing and planned wells and how it will manage the flaring to protect the community and minimise emissions?

Air pollution including greenhouse gas emissions

The project will result in approximately 300,000 tonnes of carbon dioxide equivalent per year over the 20-year lifetime of the proposal (resulting in overall emissions from the project of approximately 6 million tonnes) and will increase the State’s annual GHG emissions by approximately 0.4%.4

Mitsui/AWE’s Greenhouse Gas Management Plan does not demonstrate how the proposal will reduce net greenhouse gas emissions as is required in the new Environmental Factor Guideline for Greenhouse Gas Emissions published by the EPA on 16 April 2020. While it outlines interim and aspirational long-term emission targets, these targets are inadequate and do not demonstrate that all reasonable and practicable measures have been applied to avoid, reduce and offset the project’s scope 1 emissions over the life of the proposal.

Mitsui/AWE’s Greenhouse Gas Management Plan, Management of Flaring Plan and air dispersion modelling do not appear to model the likely substantial escape of fugitive methane emissions, or the emissions associated with construction of the gas processing plant or drilling of the wells. The air dispersion modelling also fails to include emissions from the wells, flaring at the wells and diesel generators associated with these.

You might want to ask the EPA:

  • If and how will the project reduce, rather than increase, net greenhouse gas emissions and contribute towards the aspiration of net zero emissions by 2050
  • How does Mitsui/AWE plan to monitor and minimise the project’s fugitive methane emissions? The baseline requirements under the Commonwealth Safeguard Mechanism are not strong enough and do not include detailed on the ground measurements.

[4] Based on the 2013-2014 figure of 83.4 Mt.

Clearing of native vegetation

The project involves clearing of up to 17 hectares of native vegetation and direct loss of individual plants from 4 priority listed taxa.

You might want to ask the EPA:

  • How will the EPA manage the impacts of the clearing on flora and vegetation to ensure that biological diversity and ecological integrity are maintained?

 

References:

1 https://www.irmau.com/site/PDF/2614_1/AWE39sWaitsiaSiteTourPresentation

2 ACOLA Report; US EPA 2016a; Costa et al. 2017; USGS 2017.

3 US Geological Survey 2017

4 Based on the 2013-2014 figure of 83.4 Mt.

 

 

Comments are due by Thursday 7 May here on the EPA website.

Waitisia plan

The Waitsia project is in the area where the WA Government has lifted the fracking moratorium, and Mitsui/AWE and it's partner Beach Energy have not ruled out fracking in future stages.

They've told investors there's significant potential beyond stage 2, likely to come from the tight sands gas found here that would need fracking.

To read all the information about this stage 2 proposal, see here on the EPA website. Click on 'Referral' and 'Assessment' near the bottom to access all the various management plans and the main application 'Supporting Document'(under 'Referral'). It includes plans for water usage, flaring, emissions, clearing and more, but as our concerns above note, we think there's a lot of information still missing, and concerning.