cooper basin petroleum production operations environmental...

Cooper Basin Petroleum Production Operations

Environmental Impact Report

November 2016

SENEX-CORP-EN-REP-009

Senex Cooper Basin Petroleum Production Operations Environmental Impact Report

Prepared by

Senex Energy Ltd

Level 14

144 Edward Street

BRISBANE QLD 4000

T: (07) 3837 9900

F: (07) 3837 9999

E: [email protected] W: www.senexenergy.com.au and

RPS

Level 6

33 Franklin St

ADELAIDE 5000

T: 61 8 8410 4000

F: 61 8 8410 6321

E: [email protected]

W: www.rpsgroup.com.au

Document Status

Version Purpose of Document Orig Review Review Date QA Review Release Approval

Issue Date

Rev A Draft for internal RPS review BW/LQ/SM

13 Nov 2013

Rev B Draft for Senex review BW/LQ/SM

LQ 14 Nov 2013 BW SM 14 Nov 2013

Rev C Draft for Senex Management review

TJ/GS/ TC/RF

29 Nov 013 GP 9/12/2013

Rev 0 Draft to DMITRE for comment DS 9/12/2013 DS 17/12/2013

Rev 1 Final for submission to DMITRE DMITRE 21/02/2014 TJ DS 13/10/2014

Rev 1.1 Minor Revision for Senex Review

AC TJ/MR 5/11/2016 DG

Rev 1.2 Issued to DSD for comment 11/11/2016 MR DG 14/11/2016

Rev 1.3 Issued for Stakeholder comment

Rev 2.0 Issued for Use

mailto:[email protected]

http://www.senexenergy.com.au/

mailto:[email protected]

http://www.rpsgroup.com.au/


Senex Production EIR Rev1.2 1

Contents

1 Introduction ................................................................................................ 4

1.1 Background ....................................................................................... 4

1.1.1 PEL182 Coongie Lakes Special Management Zones ....... 4

1.2 Senex Energy Company Profile ........................................................ 5

1.3 About this Document ......................................................................... 5

1.3.1 Scope ................................................................................. 6

2 Legislative Framework .............................................................................. 2

2.1 Petroleum and Geothermal Energy Act 2000 ................................... 2

2.1.1 Activity Notification / Approval Process ............................. 3

2.2 Other Legislation ............................................................................... 4

3 Production Operations .............................................................................. 7

3.1 Production Facilities .......................................................................... 7

3.1.1 Oil Production Facilities ..................................................... 8

3.1.2 Gas Production Facilities ................................................. 11

3.2 Produced Formation Water ............................................................. 13

3.2.1 Water Treatment and Disposal ........................................ 13

3.3 Waterflood ....................................................................................... 17

3.3.1 Tracers ............................................................................. 17

3.4 Pipelines / Flowlines ........................................................................ 18

3.4.1 Route Selection, Survey and Site Preparation ................ 18

3.4.2 Pipeline Construction ....................................................... 19

3.4.3 Pipeline Testing................................................................ 19

3.4.4 Site Restoration................................................................ 19

3.4.5 Operation ......................................................................... 20

3.5 Road Construction and Maintenance .............................................. 20

3.6 Aircraft Landing Area ....................................................................... 21

3.7 Oil Transport .................................................................................... 21

3.8 Waste Management ........................................................................ 22

3.8.1 Landfill – Domestic Waste ............................................... 23

3.8.2 Sewage Waste Management ........................................... 23

3.8.3 Contaminated Soil Treatment / Soil Remediation Areas . 23

3.9 Decommissioning / Rehabilitation ................................................... 24

4 Existing Environment .............................................................................. 25

4.1 PEL182 Existing Environment ......................................................... 25

4.2 Climate ............................................................................................ 25

4.3 Landforms and Land Systems ......................................................... 25

4.3.1 PEL182 Landforms, Landsystems and Soils ................... 26

4.4 Flora and Fauna .............................................................................. 30

4.4.1 Flora ................................................................................. 30

4.4.2 Fauna ............................................................................... 31

4.4.3 Threatened Species and Communities ............................ 32

4.4.4 Coongie Lakes Ramsar Wetland and EPBC Act ............. 32

4.4.5 Introduced Pest Plants and Animals ................................ 33

4.5 Surface Water .................................................................................. 33

4.6 Geology ........................................................................................... 35



4.7 Hydrogeology .................................................................................. 36

4.8 Social Environment.......................................................................... 37

4.8.1 Aboriginal Cultural Heritage ............................................. 37

4.8.2 Non-Aboriginal Cultural Heritage ..................................... 38

4.8.3 Native Title ....................................................................... 38

4.8.4 Land use .......................................................................... 38

4.9 Socio-economic ............................................................................... 40

5 Environmental Risk Assessment ........................................................... 41

5.1 Overview of Risk Assessment Process ........................................... 41

5.2 Production Facilities ........................................................................ 44

5.2.1 Facility Construction ......................................................... 44

5.2.2 Facility Operation ............................................................. 45

5.3 Produced Formation Water ............................................................. 51

5.4 Waterflood ....................................................................................... 54

5.5 Pipelines / Flowlines ........................................................................ 56

5.5.1 Pipeline Construction ....................................................... 56

5.5.2 Pipeline Operation ........................................................... 59

5.6 Road Construction and Maintenance .............................................. 67

5.7 Aircraft Landing Area ....................................................................... 72

5.8 Oil Transport (by Road) ................................................................... 74

5.9 Waste Management ........................................................................ 76

5.10 Decommissioning / Rehabilitation ................................................... 78

6 Environmental Management Framework .............................................. 82

6.1 Environmental Management System .............................................. 82

6.2 Planning ........................................................................................... 82

6.3 Environmental Management Plans ................................................. 83

6.4 Environmental Induction .................................................................. 83

6.5 Roles & Responsibilities .................................................................. 83

6.6 Environmental Procedures .............................................................. 84

6.7 Operations and Maintenance Policy ................................................ 85

7 Consultation ............................................................................................. 86

7.1 Key Stakeholder Consultation ......................................................... 86

8 References ............................................................................................. 104

9 Abbreviations and Definitions .............................................................. 108

Appendix 1: Land Systems of the Cooper Basin

Appendix 2: Threatened Species Recorded in the Region

Appendix 3: Summary of 2016 SEO / EIR Revision Changes



Tables

Table 1: Access Restrictions Summary - Coongie Lakes Special Management Zones 5 Table 2: Additional Environmental Legislation and Approvals .............................. 4 Table 3: Senex production infrastructure as at October 2016 .............................. 7 Table 4: Road construction methods for land systems in the Cooper Basin (Santos,

2003a) .................................................................................................. 20 Table 5: Typical waste streams ........................................................................... 22 Table 6: Temperature and rainfall records for Moomba (1995-2016) ................ 25 Table 7: Cooper Basin landforms and descriptions ............................................ 26 Table 8: Current Senex production facility locations and relevant landforms and land

systems ................................................................................................ 30 Table 9: Typical vegetation characteristics of landforms in the Cooper Basin ... 30 Table 10: Land systems and sites of Aboriginal artefacts................................... 37 Table 11: Native Title claims in the South Australian Cooper Basin ................... 38 Table 12: Consequence definition ....................................................................... 42 Table 13: Likelihood definition ............................................................................. 42 Table 14: Environmental risk matrix .................................................................... 43 Table 15: Risk Treatment Actions ....................................................................... 44 Table 16: Production facility risk assessment ..................................................... 46 Table 17: PFW storage and disposal risk assessment ....................................... 52 Table 18: Waterflood risk assessment ................................................................ 55 Table 19: Consequences associated with earthworks in various Cooper Basin landforms

............................................................................................................. 58 Table 20: Pipeline construction risk assessment ................................................ 61 Table 21: Pipeline operation risk assessment .................................................... 65 Table 22: Road construction and maintenance risk assessment ....................... 68 Table 23: Aircraft landing area risk assessment ................................................. 73 Table 24: Oil transport risk assessment .............................................................. 75 Table 25: Waste management risk assessment ................................................. 77 Table 26: Decommissioning / rehabilitation risk assessment ............................. 79 Table 27: Stakeholder consultation list ............................................................... 86 Table 28: Comments submitted during 2014 stakeholder consultation .............. 88 Table 29: Comments submitted during 2016 stakeholder consultation ............ 102

Figures

Figure 1: PEL 182 and the Special Management Zones ...................................... 1 Figure 2: PEL182 Special Management Zones – Walk In Zone Detail ................. 1 Figure 3: Location of Senex Energy’s current petroleum production operations in the

South Australian Cooper Basin ............................................................. 1 Figure 4: Process Diagram - Jet Pump ............................................................... 15 Figure 5: Process Diagram - Free flow, ESP and Rod Pump ............................. 15 Figure 6: Process Diagram – Produced Formation Water Treatment Process . 16 Figure 7: Cooper Basin Landforms (Source: RPS) ............................................. 28 Figure 8: Satellite Image of PEL182 with Land systems and Special Management Zones

............................................................................................................. 29 Figure 9: Satellite Image of PEL182 South-Western Corner .............................. 29

Plates

Plate 1: Senex extended production test facility at Mustang (Source: Senex, 2013) 9 Plate 2: Production facility at Growler. (Source: Senex, 2013) ............................. 9 Plate 3: Snatcher facility. (Source: Senex, 2013) ............................................... 10 Plate 4: Worrior production facility. (Source: Senex, 2013) ................................ 10 Plate 5: Example of small gas production facility (no gas compression). (Source: RPS)

............................................................................................................. 12 Plate 6: Example of a larger gas production facility in the Cooper Basin (Source: Santos

Dullingari Facility) ................................................................................ 12



1 Introduction

This Environmental Impact Report (EIR) for Senex Energy Limited’s (Senex) production operations has been prepared in accordance with current legislative requirements, in particular, with Section 97 of the South Australian Petroleum and Geothermal Energy Act 2000 (the Act) and Regulation 10 of the Petroleum and Geothermal Regulations 2013 (the Regulations).

The Act and Regulations also require the development and implementation of a Statement of Environmental Objectives (SEO). To fulfil this requirement, a revised Statement of Environmental Objectives (Senex, 2016) has been prepared in conjunction with this document.

1.1 Background

Senex Energy’s Cooper Basin production activities previously operated under three Statements of Environmental Objectives (SEO) for production operations approved under the Petroleum and Geothermal Energy Act 2000:

Victoria Petroleum Cooper Basin Petroleum Production Operations Statement of Environmental Objectives (Victoria Petroleum 2008b)

Stuart Petroleum Cooper Basin Petroleum Production Operations (Dunefield and Floodplain) Statement of Environmental Objectives (Stuart Petroleum 2008b)

Stuart Petroleum Cooper Basin Petroleum Production Operations (Gibber Uplands) Statement of Environmental Objectives (Stuart Petroleum 2011b)

Senex undertook a review of the three SEOs and associated EIRs in November 2013 resulting in the combining of multiple documents to produce a single Production Operations SEO / EIR (Senex, 2014; 2014a) to cover all of Senex’s production operations.

The 2014 EIR was then revised in November 2016 to address production operations within Petroleum Exploration License (PEL) 182. PEL182 was released for exploration by the South Australian Government in 2003 (SA Government, 2003) with special access conditions. Specials conditions are defined in the gazettal of the licence area (SA Government, 2003), which included the creation of two Special Management Zones within the tenement: a Walk In Zone (WIZ) and a Controlled Access Zone (CAZ). The gazettal also stated that specific Statements of Environmental Objectives (SEO) would need to be developed to address the access restrictions outlined in the gazettal for petroleum activities within the PEL182 Special Management Zones.

Consequently this EIR has been revised to address petroleum production operations within PEL182 and the Special Management Zones. This EIR will be used as the basis for the development of a revised SEO to meet the requirements of the PEL182 gazettal special conditions (Senex, 2016). See Tables A3-1 to A3-2 in Appendix 3 for a summary of changes made to the revised SEO and EIR.

Note: the Stuart Petroleum Gibber Uplands SEO (Stuart Petroleum 2011b) remains in place to the extent it

covers a specific set of environmental risks for production in gibber land systems (e.g. Acrasia field) which are beyond those generic to petroleum production.

1.1.1 PEL182 Coongie Lakes Special Management Zones

PEL182 lies within a large area defined as the Coongie Lakes Ramsar wetland and the tenement surrounds the Coongie Lakes National Park (NP). The Ramsar wetland and National Park represent areas of environmental conservation significance. As such, The Coongie Lakes National Park and the Coongie lakes Special Management Zones were developed by PIRSA (now DSD) prior to the release of the PEL182 licence area, and the gazettal of the Coongie Lakes National Park.



PEL182 surrounds the National Park and the adjacent No Go Zone, as shown in

Figure 1. Within PEL182 itself, two types of Special Management Zone have also been defined: a Walk In Zone (WIZ) and a Controlled Access Zone (CAZ).

The National Park and No Go Zone were developed to protect areas of high conservation significance, particularly key water bird habitat, and the WIZ was designed to provide an additional buffer to these areas. There is no access for petroleum activities in the National Park or the No Go Zone. The Coongie Lakes wetland supports numerous migratory bird species; however the wetland and bird habitats are located outside PEL182 (and are protected by the National Park, No-Go Zone, and a Walk-In Zone buffer).

Within PEL182, the WIZ and CAZ impose access restrictions for petroleum activities that were outlined in the gazettal of the proposed PEL182 area. Additional information published by PIRSA (now DSD) identified that the proximity of environmentally sensitive wetlands and freshwater lakes was the basis for specifying the additional access restrictions for these zones, and that the key objective of the zones is to provide clear measures of protection for creek channels and associated riparian vegetation, particularly from the potential for oil leakage or spills.

The WIZ abuts Coongie Lakes NP and the No Go Zone. It provides a buffer zone, where surface restricted to foot-based geophysical surveying only (i.e. no surface vehicular production are permitted in this zone, but well surface locations (e.g. deviated

must be located outside the zone. These restrictions also apply to a second small



PEL182 covering a key waterhole and associated riparian vegetation (see

Figure 2). The total size of the WIZ is approximately 255 km2.

The CAZ is located along the western edge of PEL182. It contains a major creek / floodplain area that also has significant environmental, social and cultural values

1. The gazettal

1 states that another type of access restriction

intended to provide appropriate protection as well as access for petroleum exploration and development has been applied to the CAZ, and that it will have conditions set for access that are over and above normal environmental management requirements and practices undertaken for the rest of the Cooper Basin. Indicative access conditions for the CAZ were published in the gazettal

1 and are summarised in Table 1. The total size of the CAZ

is 244 km2.

Table 1: Access Restrictions Summary - Coongie Lakes Special Management Zones

Walk In Zone

Subsurface drilling / production is permitted.1

Surface access is restricted to foot-based geophysical surveying (i.e. without surface vehicular access).

1

Wells may be drilled into the subsurface of this zone from locations outside the zone.2

Production pipelines and flowlines are not permitted to extend into this zone.2

Controlled Access Zone

No earthmoving in periods of flood.1

No drilling within 300 m of a major creek channel.1

No trucking of oil during flood periods.1

(Note: the Moomba plant lies 80 km south of the PEL182 area and ‘normal’ access through north-south corridors either side of the control and no-go zones and national park would still be permitted, subject to Petroleum and Geothermal Energy Act 2000

requirements).2

All creek crossings of pipelines to be buried and incorporate two physical mechanisms of oil spill protection and two systematic mechanisms of oil spill protection.

1

No blockage of any creek channel.1

1 South Australian Government Gazette,14 July 2003, pages 2928-2931.



2 PIRSA (2003). Cooper Basin Acreage Release, Block CO2003-A. 11 July 2003. Primary Industries and Resources South

Australia.

1.2 Senex Energy Company Profile

Senex Energy is a diversified Australian energy company based in Brisbane with a long-standing history in the oil and gas industry. Senex is a major oil producer in the South Australian Cooper Basin, with a strong acreage position on the Cooper Basin's western flank. The company is pursuing a rapid development strategy in its Cooper Basin acreage, targeting a significant increase in oil reserves and production capability in the short to medium term.

Senex is also working towards developing a large-scale, cost-competitive unconventional gas resource in the Cooper Basin. The company gained a substantial portfolio of unconventional gas acreage when it acquired Stuart Petroleum Limited in 2011. It has subsequently expanded its portfolio through key farm-ins to have a commanding position in some of the Cooper Basin's most prospective areas for unconventional gas.

The current locations of Senex’s petroleum production operations are shown in Figure 3.

1.3 About this Document

This document has been prepared to satisfy the requirements of an Environmental Impact Report (EIR) under the Petroleum and Geothermal Energy Act 2000. It has been prepared in accordance with current legislative requirements, in particular Section 97 of the Act and Regulation 10 of the Petroleum and Geothermal Energy Regulations 2013 in conjunction with a review of the existing SEO.

An EIR on regulated activities must take into account cultural and amenity values, risks inherent in the regulated activity to the health and safety of the public, and must contain sufficient information to make possible and informed assessment of the likely impact of the activities on the environment.

Under the P&G Act and Regulations an annual report must be prepared which must include key matters such as a summary of the regulated activities, compliance and actions to rectify non-compliance, an assessment of incidents and effectiveness of any action taken, a summary of data and technical reports and an estimate of future development activities.

The intent of the SEO is to outline the environmental objectives to which production operations in the Cooper Basin will conform, and the criteria upon which the achievement of these objectives will be assessed. Under section 14 of the Regulations an approved SEO must be reviewed at least once in every 5 years.

This document is based on information contained in a number of existing EIRs, including:

Victoria Petroleum Cooper Basin Petroleum Production Operations (Victoria Petroleum 2008a)

Stuart Petroleum Cooper Basin Petroleum Production Operations (Dunefield and Floodplain) (Stuart Petroleum 2008a)

Stuart Petroleum Cooper Basin Petroleum Production Operations (Gibber Land Systems) (Stuart Petroleum 2011a).

South Australian Cooper Basin Joint Venture Environmental Impact Report: Production and Processing Operations (Santos 2003a; 2010)

South Australian Cooper Basin Joint Venture Environmental Impact Report: Waterflood Pilot Project (Santos 2003b)

South Australian Cooper Basin Parties Addendum to Environmental Impact Report: Production and Processing Operations (Santos 2010)

Beach Energy Addendum to the Environmental Impact Report: Cooper Basin Petroleum Production Operations. (November, 2009).

Senex Energy PEL182 Controlled Access Zone Drilling, Completions and Well Operations Environmental Impact Report (Senex, 2016a).



Senex Energy Geophysical Operations in PEL182 Cooper Basin, Environmental Impact Report (Senex, 2013).

Generic information in this report has been based on the EIR developed by Santos Ltd for production and processing operations in the Cooper Basin (Santos 2003a; 2010). The Santos EIR provided baseline information for this EIR including detailed information on the environment of the Cooper Basin and the environmental risks and consequences gathered over more than 30 years of operations in the Cooper Basin. The information present in the Santos EIR is not duplicated in detail in this report.

1.3.1 Scope

This EIR addresses potential environmental risks and consequences associated with Senex’s production operations in the Cooper and Eromanga Basins (including PEL182 and the Controlled Access Zone (CAZ)) (see

Figure 1 to Figure 3). It has been written to address both current and potential future production activities in all land systems in the Cooper Basin, in order to develop a SEO that will address reasonably foreseeable future activities over the lifetime of the SEO.

Production operations in the future (e.g. production at new sites) will be assessed against this EIR and the revised SEO to demonstrate that the EIR and SEO are applicable as discussed in Section 2.1.1. This assessment will be submitted to Department of State Development (DSD) as a component of the Activity Notification, as required by Regulations 19 and 20 of the Petroleum and Geothermal Energy Regulations 2013. In some cases it may be necessary to produce a bridging document or brief EIR to supplement this EIR if it does not adequately address risks and consequences associated with the change.

The sites addressed specifically in this EIR are located on pastoral leases and the Innamincka and Strzelecki Regional Reserves. While risks and consequences of production operations are not different inside Regional Reserves, any future production operations inside Regional Reserves will



require additional approval of the Production Licence from the Minister responsible for the National Parks and Wildlife Act 1972.

Senex activities that are specifically covered by this EIR include:

Well operation and maintenance pipeline, trunkline and flowline construction, operation and abandonment production facility construction, operation, maintenance and abandonment (including extended

production test facilities, camps and operational areas such as laydowns) produced formation water disposal operations waterflood activities for enhanced oil recovery road construction, maintenance and restoration waste management and land treatment unit operations

This EIR and the accompanying SEO do not apply to:

exploration activities drilling activities sub-surface well / reservoir activities (with the exception of the aspects related to waterflood that

are covered in the SEO) fracture stimulation well site and access track construction well completion pre-wellhead production down hole abandonment restoration of well sites and access tracks seismic operations

These activities are covered by other SEOs including:

South Australia Cooper Basin and Arid Regions Geophysical Operations - Statement of Environmental Objectives (Santos 2012b)

South Australia Cooper Basin Operators Statement of Environmental Objectives: Drilling, Completions and Well Operations (Santos 2015).

Statement of Environmental Objectives: Fracture Stimulation of Deep Shale Gas and Tight Gas Targets in the Nappamerri Trough (Cooper Basin), South Australia (Beach 2012b).

Geophysical Operations in PEL182, Cooper Basin Statement of Environmental Objectives, (Senex 2013).

Senex Energy Fracture Stimulation of Oil Targets of the Eromanga Basin Formations in the Cooper Basin, South Australia – Statement of Environmental Objectives (Senex, 2015)

Senex Energy PEL182 Controlled Access Zone Drilling, Completions and Well Operations Environmental Impact Report (Senex, 2016a).



Figure 1: PEL 182 and the Special Management Zones

Figure 2: PEL182 Special Management Zones – Walk In Zone Detail



Figure 3: Location of Senex Energy’s current petroleum production operations in the South Australian Cooper Basin



2 Legislative Framework

This section briefly describes the legislative framework that currently applies to petroleum activities in South Australia.

2.1 Petroleum and Geothermal Energy Act 2000

Petroleum production activities are governed by the Petroleum and Geothermal Energy Act 2000 and the Petroleum and Geothermal Energy Regulations 2013. This legislation is administered by Department of State Development.

The key objectives of the legislation include:

to create an effective, efficient and flexible regulatory system for exploration and recovery or commercial utilisation of petroleum and other regulated resources

to minimise environmental damage from the activities involved in exploration and recovery or commercial utilisation of petroleum and other regulated resources

to establish appropriate consultative processes involving people directly affected by regulated activities and the public generally

to protect the public from risks inherent in regulated activities.

Regulated activities, as defined in Section 10 of the Act, are:

exploration for petroleum or another regulated resource operations to establish the nature and extent of a discovery of petroleum or another regulated

resource, and to establish the commercial feasibility of production and the appropriate production techniques

production of petroleum or another regulated substance utilisation of a natural reservoir to store petroleum or another regulated substance production of geothermal energy construction of a transmission pipeline for carrying petroleum or another regulated substance operation of a transmission pipeline for carrying petroleum or another regulated substance.

Statement of Environmental Objectives

As a requirement of Part 12 of the Act, a regulated activity can only be conducted if an approved Statement of Environmental Objectives (SEO) has been developed. The SEO outlines the environmental objectives that the regulated activity is required to achieve and the criteria upon which the objectives are to be assessed. Under Regulation 14 of the Petroleum and Geothermal Energy Regulations, an approved SEO must be reviewed at least once in every five years.

Environmental Impact Report

In accordance with Section 97 of the Act, the EIR must:

take into account cultural, amenity and other values of Aboriginal and other Australians in so far as those values are relevant to the assessment

take into account risks to the health and safety of the public inherent in the regulated activities contain sufficient information to make possible an informed assessment of the likely impact of

the activities on the environment.

As per Regulation 10 of the Petroleum and Geothermal Energy Regulations 2013 the following information must be provided for the purposes of an EIR:

a description of the regulated activities to be carried out under the licence (including their location)

a description of the specific site features of the environment that can reasonably be expected to be affected by the activities, with particular reference to the physical and biological aspects of the environment and existing land uses

an assessment of the cultural values of Aboriginal and other Australians which could reasonably be foreseen to be affected by the activities in the area of the licence, and the public health and safety risks inherent in those activities (insofar as these matters are relevant in the particular circumstances)



a description of reasonably foreseeable events associated with the activity that could pose a threat to the relevant environment (including events during the construction, operational and abandonment stages, atypical events, estimated frequency of events and the basis of predictions)

an assessment of the potential consequences of these events on the environment (including size and scope, duration, cumulative effects and proposed management actions)

an explanation of the basis on which these consequences have been predicted a list of all owners of the relevant land information on consultation undertaken during the preparation of the EIR.

Assessment and Approval

The EIR is submitted to DSD and an Environmental Significance Assessment is undertaken to determine whether the activities described in the EIR are to be classified as ‘low’, ‘medium’ or ‘high’ impact. A corresponding SEO is prepared, reflecting the impacts and measures identified in the EIR or other assessments that may be required as determined by the classification.

The classification also determines the level of consultation DSD will be required to undertake prior to final approval of the SEO as follows:

Low impact activities do not require public consultation and are subjected to a process of internal government consultation and comment on the EIR and SEO prior to approval.

Medium impact activities require a public consultation process for the EIR and proposed SEO, with comment sought for a period of at least 30 business days.

High impact activities are required to undergo an environmental impact assessment under the provisions of the Development Act 1993.

The level of impact of a particular activity is assessed on the basis of the predictability and manageability of the impacts on the environment. Where the environmental impacts are predictable and readily managed, the impact of the activity is considered low. Where the environmental impacts are less predictable and are difficult to manage, the impact of the activity is potentially high.

Once the approval process is complete, all documentation, including this EIR and its associated SEO, must be entered on an environmental register. This public Environmental Register is accessible to the community from the DSD website.

2.1.1 Activity Notification / Approval Process

Prior to commencing a regulated activity, Section 74(3) of the Petroleum and Geothermal Energy Act requires that:

The Minister’s prior written approval is required for activities requiring high level supervision (as per Regulation 19), and

Notice of activities requiring low level supervision is to be given at least 21 days in advance (as per Regulation 18).

In order to obtain written approval for activities requiring high level supervision, an application and notification of activities (in accordance with Regulation 20) must be submitted to the Minister at least 35 days prior to the commencement of activities.

The notification of activities must provide specific technical and environmental information on the proposed activity and include an assessment to demonstrate that it is covered by an existing SEO.

Consequently, the activity notification process provides an additional opportunity for DSD to ensure that the proposed activities and their impacts can be effectively managed and are consistent with the approvals obtained in the EIR and SEO approval process. This is particularly relevant for activities that are conducted under an SEO that applies to a broad geographical area, as it provides site-specific detail that is not usually contained in the generic documents.



2.2 Other Legislation

A number of additional environmental approvals may be required under Commonwealth and South Australian legislation. These are outlined in Table 2 (Note: Table 2 is not a comprehensive list of all applicable legislation). It must be noted that not all subsequent approvals are mandatory at the development (or construction) stage, as approvals may be required as circumstances arise (for example cultural artefact finds during construction or operation).

Table 2: Additional Environmental Legislation and Approvals

Agency Legislation Issue

Commonwealth

Department of the Environment and Energy

(DoEE)

Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)

Assessment and approval required if activities will significantly impact matters of national environmental significance, including:

National Heritage Places

wetlands of international importance (Ramsar wetlands)

listed threatened species and communities

listed migratory species (for example JAMBA and CAMBA)

Commonwealth Native Title Act 1993 Intersection of registered Native Title claims

South Australia

Aboriginal Affairs and Reconciliation (AAR), Department of State Development (DSD)

Aboriginal Heritage Act 1988 Where a planned activity is likely to damage, disturb or interfere with a site or object, authorisation must first be obtained from the Minister for Aboriginal Affairs and Reconciliation under Section 23 of the Act.

Environment Protection Authority (EPA)

Environment Protection Act 1993

Radiation Protection and Control Act 1983

General environmental duty to avoid causing environmental harm

Licensing of scheduled / prescribed activities e.g.

Establishment of landfill site for waste disposal

Transport of prescribed wastes or substances

Producing listed wastes

Storage or production of large volumes of petroleum (2000 m

3 storage or 20 tonnes per hour production)

Fuel burning at a rate of heat release exceeding 5 megawatts

Injection of fluid containing antibiotic or chemical water treatments at a rate of more than 50 kL / day

Regulating use of ionising sources of radiation including storage, transport and disposal.

Senex operates under an EPA licence (Licence No. 43202)

Department of Environment, Water and Natural Resources (DEWNR)

Heritage Places Act 1993 Permission required if listed heritage places or related objects are to be destroyed /disturbed

DEWNR National Parks & Wildlife Act 1972 ‘Taking’ of protected plant and animal species

Undertaking regulated activities in Regional Reserves

DEWNR Native Vegetation Act 1991

Removal of native vegetation and achievement of significant environmental benefit (SEB)

DEWNR Crown Land Management Act 2009

Provision for the disposal, management and conservation of Crown Land in South Australia.

DEWNR Pastoral Land Management and Conservation Act 1989

Provides for the management and conservation of pastoral land to ensure that all pastoral land in SA is well managed and utilized to maintain renewable resources and yields sustained.

DEWNR

SAAL NRM Board

Natural Resources Management Act 2004

Management of pest plants and animals

Water allocation (e.g. from water bores, co-produced water)

Water affecting activities (e.g. water well construction)



Agency Legislation Issue

SA Attorney General’s Department

Native Title (South Australia) Act 1994

Matters relating to traditional land rights in South Australia. The Act provides for the registration of native title rights, investigations on native title rights, claims and determinations of native title rights and compensation for acts affecting native title rights.

Safework SA Explosives Act (South Australia) 1936

The Explosives Act and regulations regulate the manufacture, carriage, storage, import and purchase or explosives.

Safework SA Work Health and Safety Act 2012 Identifies control measures to be applied to specific work activities and hazards.

Other South Australian legislation of particular relevance to the proposed activities may also include:

Fire and Emergency Services Regulations 2005 – in relation to fire bans and hot work permits;

The Dangerous Substances Act 1979 – in relation to the keeping, handling, transporting, conveyance, use and disposal, and the quality, of dangerous substances; and

South Australian Public Health (Wastewater) Regulations 2013 – in relation to waste water (sewage) disposal and the operation of septic tank systems with respect to the Department of Health’s requirements / approval.

EPBC Act

The Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) provides the regulatory framework for the protection of Matters of National Environmental Significance (MNES). Assessment and approval under the EPBC Act is required if an activity will, or is likely to, significantly impact MNES, including World Heritage properties, National Heritage places, wetlands of international importance (Ramsar wetlands), listed threatened species and ecological communities, and listed migratory species (e.g. Bilateral Migratory Bird Agreements JAMBA, CAMBA and ROKAMBA) and a water resource, in relation to coal seam gas development and large coal mining developments and activities related to nuclear energy, including uranium mining.

In regard to petroleum activities in the Cooper Basin, issues that potentially require approval under the EPBC Act are relatively limited and can generally be avoided by site selection and implementation of field procedures (e.g. avoiding impacts to surface drainage and significant wetland areas). Senex will continue to review proposed activities against the EPBC Act triggers and will submit a referral under the Act for specific activities if necessary.

EPBC Act and PEL182

PEL182 lies within the large area defined as the Coongie Lakes Ramsar wetland and this is further discussed in detail in Section 4.4.4. The Coongie Lakes wetland supports numerous migratory bird species; however the key wetland and bird habitats lie outside PEL182 (and are protected by the National Park, No-Go Zone, and a Walk-In Zone buffer).

Seismic surveys and exploratory drilling have previously been carried out over the region containing PEL182 (including parts of what is now the Coongie Lakes National Park) with generally low to negligible impacts and limited ongoing or long term effects (e.g. see Reid, 1998; Cockshell et al., 1998a; 1998b).

Senex shall carry out production operations within PEL182 and associated CAZ in accordance with all applicable legislation, regulations, standards and environmental objectives (including the specific requirements for operating within the PEL182 Special Management Zones) to ensure activities avoid or minimise environmental impacts.

Consequently, the proposed activities are not expected to have a significant impact on any MNES (e.g. listed threatened species, Ramsar wetland, and listed migratory species). Senex considers that a requirement for approval under the EPBC Act is not likely to be triggered and that a referral of the proposal to the Commonwealth Department of the Environment and Energy (DoEE) under the EPBC Act is not required.

Senex will continue to review the site specific details of proposed production operations within PEL182 against the relevant EPBC Act significance criteria to ensure this assessment remains valid.



Native Vegetation Act and Regulations

The South Australian Native Vegetation Act 1991 and the Native Vegetation Regulations 2003 apply to vegetation clearance for petroleum operations. Under Regulation 5(1)(zd), petroleum operations are permitted to clear native vegetation, provided that either:

the clearance is undertaken in accordance with a SEO and the Native Vegetation Council has signified that, as a result of work undertaken in accordance with the SEO, there will be a ‘significant environmental benefit’ (SEB) at the site of the operations or within the same region of the State, or

the project makes a payment into the Native Vegetation Fund of an amount considered by the Native Vegetation Council to be sufficient to achieve a ‘significant environmental benefit’.

A ‘significant environmental benefit’ is typically achieved by undertaking works to establish, regenerate, preserve or maintain native vegetation. Guidelines

1 have been developed for the minerals

and petroleum industry to provide a framework for determining the level and method of SEB. These guidelines are administered by DSD, who have delegated authority to approve SEBs.

A requirement to achieve a SEB will be included in the accompanying SEO.

1 Dept. of Water, Land & Biodiversity Conservation (2005) Guidelines for a Native Vegetation Significant Environmental Benefit

Policy for the clearance of native vegetation associated with the minerals and petroleum industry. Prepared for the Native Vegetation Council, September 2005.



3 Production Operations

This section provides a description of production operations that are currently being or likely to be carried out by Senex in the Cooper Basin.

Production operations have been grouped into the following categories:

production facilities (including oil and gas production facilities, and support infrastructure) produced formation water disposal waterflood activities pipelines / flowlines road construction and maintenance aircraft landing area oil transport by road waste management decommissioning / rehabilitation.

Production operations and ancillary activities can be undertaken under a number of different types of licence under the Petroleum and Geothermal Energy Act, including Petroleum Production Licence (PPL), Petroleum Retention Licence (PRL), Petroleum Exploration Licence (PEL) (e.g. extended production tests), Pipeline Licence (PL) and Associated Activities Licence (AAL) (e.g. for roads or pipelines outside Senex’s PELs or PPLs). Figure 3 provides an overview of Senex’s current licence areas and production sites in the Cooper Basin.

3.1 Production Facilities

Senex currently operates 14 production facilities in the South Australian Cooper Basin, as outlined in Table 3. These facilities all produce oil; however Senex is expecting to begin operation of the Vanessa gas facility in the near future. Consequently, the operation of both oil and gas facilities is discussed in the following subsections.

Additional oil and gas production facilities are also likely to be installed in the future if ongoing exploration drilling results in further oil and gas discoveries.

Table 3: Senex production infrastructure as at October 2016

Field / Facility Licence Wells Ponds

EPT / facility

Camp Flowlines Bulk

Storage Ware- house

Acrasia PPL 203 6 6 1 1 6

Burruna PPL 251 3 3 1 1

Growler PPL 242 14 3 2 1 11 1 1

Harpoono PPL 209 2 3 1 2

Martlet PRL 137 3 3 1 3

Mirage PPL 213 6 2 1 1 2

Mustang PPL 243 1 2 1 1

Padulla PPL 221 2 3 1 2

Snatcher PPL 240 11 3 1 10

Spitfire PPL 258 7 1 8

Ventura PPL 214 2 2 1 1

Vintage Crop PPL 241 5 2 1 2

Worrior PPL 207 10 3 1 1 9

Vanessa (operation pending)

PRL135 1 1 1

1



3.1.1 Oil Production Facilities

Oil production facilities may consist of:

gathering system (flowlines) from the oil well(s) well facility and pumping systems inlet manifold system water separator tank(s) skimmer tank crude oil separation and oil storage tanks pigging facilities (launch and receiver stations) oil transfer pumps drains and sump utilities (instrument air, electric power generation, fuel gas and fuel oil systems) at selected

facilities office, amenities and accommodation (at selected facilities) bulk storage areas or warehouse (at selected facilities) potable water treatment system (e.g. reverse osmosis system) (at selected facilities) telemetry and communications system emergency shutdown and control systems produced water treatment facilities, including interceptor ponds, holding ponds and

evaporation ponds chemical injection system for corrosion prevention and emulsion breaking lined and bunded tanker load-out area piping connections to an oil pipeline hazardous material storage areas wastewater and sewage treatment systems perimeter fencing.

The area of a production facility (excluding ponds for water disposal) is typically in the order of 250 m x 250 m.

Electrical power for the facility and the nearby oil fields is provided by electrical generation equipment at the site.

Potable water may be obtained from third party facilities, or appropriately licensed water bore. Reverse osmosis units may be used in the future to treat bore water to ensure that it is suitable for drinking.

Artificial lift (e.g. rod pumps, jet pumps and electric submersible pumps) may be used on oil wells. Consequently, pumps and high pressure flowlines may be located within the boundary of a production facility. Flowlines are covered by this document, however artificial lift is addressed in the Drilling, Completions and Well Operations EIR and SEO (Santos, 2015).

In the event that additional or new facilities are required, the facilities are located, where possible on previously disturbed ground. The majority of facilities are usually located on pre-existing drill pads or adjacent to producing wells. This assists in minimising the extent of any additional earthworks and allows existing access tracks to be utilised. However, an additional area may need to be cleared and / or fill imported to provide for facility foundations or bunds.

Camp accommodation and laydown / storage areas (for stockpiling materials and equipment) are established at selected sites. These are established in existing areas of disturbance where possible, or in areas with little perennial vegetation. They would typically be located adjacent to existing roads or tracks.



Plate 1: Senex extended production test facility at Mustang (Source: Senex, 2013)

Plate 2: Production facility at Growler. (Source: Senex, 2013)



Plate 3: Snatcher facility. (Source: Senex, 2013)

Plate 4: Worrior production facility. (Source: Senex, 2013)



Processes

Oil production facilities receive fluids from oil producing well(s), separate the gas and water from the oil, and then transfer the processed oil to storage tanks. Oil is then transported from the site to third party facilities either by truck or via pipeline.

The water content of fluid produced from an oil well can vary with Senex’s fields typically varying between nil and 95%. After separation from the oil in separator tanks, produced water flows via pipes to a series of ponds for further separation, as discussed in Section 3.2.

A pressure relief system is installed at sites for both plant venting and emergency relief, and in some cases may also include a flare system.

Management of produced formation water, domestic and other wastes and contaminated soil at oil production facilities is discussed in Sections 3.2 and 3.8.

3.1.2 Gas Production Facilities

Raw gas is delivered to gas production facilities via pipelines from producing wells. Gas facilities then deliver raw gas (usually pressure-boosted) to the Cooper Basin pipeline network (which feeds the Moomba processing plant).

A typical gas facility incorporates:

gathering and manifold system from the gas wells an inlet header system for raw gas gas, liquid hydrocarbon (condensate) and water separation facilities gas compression and cooling systems gas conditioning (oxygen and CO2 removal) facilities condensate handling facilities liquid hydrocarbon recovery slug catchers (separation) pigging facilities (launch and receiving stations) telemetry and communications system emergency shutdown and control systems utility facilities, including fuel gas system, fire detection, instrument air, evaporative office, amenities and accommodation coolers, emergency power generation and wash-down water produced water treatment facilities, including interceptor ponds and evaporation ponds a flare system and vent facilities piping connection to a trunkline perimeter fencing.



Plate 5: Example of small gas production facility (no gas compression). (Source: RPS)

Plate 6: Example of a larger gas production facility in the Cooper Basin (Source: Santos Dullingari Facility)

Processes

A gas facility generally provides its own fuel gas system. Electrical power is usually generated on site but may be provided from other sources.

Raw gas enters a gas facility where it is separated into the three component phases - gas, hydrocarbon liquid and water (produced formation water) - inside inlet separator vessels.

Once separated, the natural gas component may then be supplied directly to a third party as raw or compressed gas. Any remaining condensed hydrocarbon liquid in the gas is recovered in separators and generally reinjected into the discharge header or stored and trucked offsite. The gas (or gas and condensate mixture) is transported from the site via a pipeline connection to another gas facility or direct to a third party.

After gas separation in separator vessels, produced water flows via pipes to a series of ponds for further separation, as discussed in Section 3.2.

A pressure relief system is provided for both plant venting and emergency relief. During any process anomalies or emergency situation, gas in the plant can be sent directly to the relief system.



During extended production tests that are conducted to evaluate new gas discoveries, gas wells that are not close to an existing gathering network may be flared to allow reservoir parameters and commerciality to be established. Ministerial approval will be sought for production (flaring) of a regulated substance under a PEL for more than 10 days.

As discussed in Section 3.1.1, new facilities are located where possible on previously disturbed ground to assist in minimising the extent of any additional earthworks and allow existing access tracks to be utilised.

Management of produced formation water and domestic and other wastes at gas production facilities is discussed in Sections 3.2 and 3.8.

3.2 Produced Formation Water

When oil or gas is produced to the surface it is accompanied by varying quantities of water2. This

water is known as produced formation water (PFW) and following removal of the petroleum products at the facility the remaining water is treated for disposal.

Once PFW undergoes primary treatment, it is then transferred to a lined interceptor pond. From this point there are two options for treatment and disposal of the PFW; either disposal to evaporation ponds or injection / infiltration to near surface aquifers. The treatment process for PFW is shown in Figure 6.

PFW passes via a pipe system into an interceptor pond where any entrained hydrocarbons are recovered by manual skimming or vacuum truck. The separated water then passes through a series of ponds (as discussed in Section 3.2.1). The process is designed to achieve an oil-in-water content of:

less than 30 mg / L if the water is being disposed of via closed (bunded) evaporation ponds; or less than 10 mg / L if the water is directed to free-form (unbunded) evaporation ponds or

infiltration basins.

The above oil-in-water content criteria are based on recommended standards that have been provided by DSD for formation water ponds in the South Australian Cooper Basin (Santos 2003a; 2010).

3.2.1 Water Treatment and Disposal

Primary Treatment

Primary treatment can be either physical (gravity) separation and / or chemical treatment where needed. Chemical treatment enhances PFW separation and aims to maximise hydrocarbon recovery prior to disposal. Primary treatment takes place in vessels and tanks (the separation plant) located in the vicinity of the PFW disposal facility. Water is discharged from the base of the tanks to a lined interceptor pond in the disposal system as shown in Figures 3 and 4.

Secondary Treatment - Interceptor Ponds

Interceptor ponds are the first pond in the system and are lined with an impervious membrane and fenced to prevent stock access. The interceptor ponds are used as a buffer to ensure that any hydrocarbons carried over from primary separation process do not enter subsequent unlined ponds. Hydrocarbons entering the system may pass through an oil absorbent boom if required and any remaining oil can be manually skimmed or vacuumed from the surface of the interceptor ponds.

Water exits the first interceptor pond at the opposite end to the inflow pipe by an overflow into the second interceptor pond. Water then exits the second interceptor pond via an underflow pipe to

2 The Minister for Mineral Resources and Energy holds a water license within the Far North Prescribed Wells Area (Far North

PWA) which allocates 21,900ML per annum (equivalent to 60ML/day) for the purpose of taking produced formation water pursuant to section 146 of the Natural Resource Management Act, 2004



prevent hydrocarbons on the surface moving into the evaporation pond. Any water leaving an interceptor pond must have a concentration of not more than 30 mg/L of hydrocarbon.

Tertiary Treatment - Evaporation Systems

The most common means of PFW disposal is the use of a pond system to evaporate water. There are many variables in design of evaporation systems. For example they can either be opened (with appropriate approval), closed, bunded or free form. Whether a system is open or closed depends upon water quality considerations and consultation with pastoral lessees and environmental assessment and approval. Residence times in the tertiary treatment system are planned to be sufficient for removal of hydrocarbons to meet the relevant oil in water content criteria.

Bunded evaporation systems consist of a series of specially constructed shallow ponds, typically lined with clay or an impervious liner, to which PFW is discharged, whilst free form water disposal utilises natural landscape features to form the final evaporation pond in the system.

Free form evaporation systems require at least two specially constructed and bunded interceptor ponds prior to discharge into a holding pond. Following a suitable residency time in the bunded holding pond (third pond, typically lined with clay or an impervious liner) the PFW is released into the freeform pond. The holding pond acts as a safety mechanism in the event of a hydrocarbon release to the system. Residence times within the water treatment system and ponds are designed to allow for the effective removal of hydrocarbons and ensure the discharged PFW has a hydrocarbon content of less than 10mg/L.

In addition to hydrocarbons, PFW may have variable salinity depending on the water quality of the formation where the water is being produced. In cases where a freeform evaporation pond is proposed and PFW water quality is poor due to high salinity further evaluation of the potential for impacts from salinization would be required.

Infiltration Systems

Disposal of PFW by deliberate infiltration requires the excavation of a pit through clay layers into permeable material. Water is discharged to the pit and gravity infiltrates into permeable sub-surface layers or shallow aquifers.

The infiltration method poses a risk of uncontained groundwater contamination, it is necessary to carry out rigorous testing of water quality both in the infiltration pit and at nearby groundwater bores.

This method is used by Senex for disposal of PFW in gibber uplands at the Acrasia field, and is covered by the Acrasia EIR and SEO (Stuart Petroleum 2011a and 2011b) as discussed in Section 1.1.



Figure 4: Process Diagram - Jet Pump

Figure 5: Process Diagram - Free flow, ESP and Rod Pump



Figure 6: Process Diagram – Produced Formation Water Treatment Process



Secondary Use of PFW

As PFW is a potentially contaminated process by-product, its use for secondary purposes such as drilling and hydraulic fracturing, road construction, hydrotest water, dust stabilisation or livestock watering is preferred but strictly controlled. Prior to secondary use, monitoring results must have shown that the concentration of hydrocarbons in the evaporation pond water is consistently lower than 10mg / L.

PFW may be used as a water source for waterflood, as discussed in Section 3.3. Additionally, PFW may occasionally be used as a drilling water source, depending upon water quality requirements. The secondary use of PFW as ballast water for oil field tankers is acceptable provided that the ballast, when not required, is discharged to an approved PFW disposal facility. Ballast water is discharged directly to interceptor ponds to enable any free residual oil to separate from the water and be recovered via surface skimming. Only ballast water is discharged from oil field tankers to interceptor ponds and under no circumstances is oil, condensate or fluid with greater than 30 mg / L hydrocarbon content discharged from oil field tankers to interceptor ponds.

3.3 Waterflood

Waterflooding is a means of improving oil recovery by maintaining the pressure in the formation and improving the sweep efficiency. Maintaining the pressure is accomplished by injecting produced formation water back into the formation from which it was produced or injecting water from other produced wells that have compatible water quality into the target formation

Prior to a waterflood scheme being initiated the water is tested to ensure it meets certain requirements. The injected water must be clear, stable and be of similar quality to the water in the formation that it is to be injected into. It also must not be severely corrosive and must be free of materials that may plug the formation. In order to achieve this, the PFW may be de-aerated, softened, filtered, chemically treated and / or stabilised.

PFW to be used for waterflood is typically produced into tanks, and further separation is undertaken to ensure that all the oil and sediment have been removed from the water prior to reinjecting into the formation. This is typically done using hydrocyclones, with chemicals and / or heating. Water may also be treated to kill any bacteria residing in the water and other chemicals may be added to eliminate the oxygen content or other components in the water that may cause corrosion of tubulars or incompatibility of the water injected formations.

The water is reinjected into injection wells using pumps at pressures high enough to enter the formation injected into. An injection well may be an existing well that was utilised previously for production and is converted to a water injection well or it may be specifically drilled for water injection under the South Australia Cooper Basin Operators Statement of Environmental Objectives: Drilling, Completions and Well Operations (Santos 2015). The injection wells may change over the course of the life of the field to ensure that the pool is swept in the most efficient manner.

3.3.1 Tracers

Tracers may be added to injected water to monitor the direction and effectiveness of the waterflood. Tracers are injected into the water injection well and special lab tests are conducted to pick up extremely low levels of tracer in the produced water.

Tracers are usually non-hazardous chemical or low-level radioactive tracers such as tritium or isotopes of iodine. Tritium tracer, which is effectively tritiated water (HTO), is a weak beta emitting isotope that has negligible external radiological effect. The radiotracer is typically contained in small volumes (e.g. less than 15 mL) inside approved injection vessels, resulting in negligible internal radiological hazard from possible ingestion of tracer as it is in a sealed system. A beta emitting tracer (e.g. iodine 131) may be added to the vessels to indicate when the tracer has moved through the vessels into the injection well. Tracers such as tritium and iodine tracers are used due to their inherent safety and low cost.



3.4 Pipelines / Flowlines

Pipelines are used to connect wellheads to production facilities, and to connect production facilities to the Cooper Basin pipeline network (or directly to the Moomba plant).

Lower pressure pipelines (up to 1000 psi) that transport oil from wellheads to production and storage facilities are often referred to as flowlines. Higher pressure flowlines (up to 3500 psi) may also be used in association with jet pumps to provide artificial lift (refer Santos 2014 and Senex 2014).

Pipelines are typically constructed of steel, glass reinforced epoxy (GRE) or spoolable composite pipe. High density polyethylene (HDPE) pipelines can also be used primarily for transferring water (typically PFW) between facilities and disposal ponds. Flowlines typically range in size from 50 mm to 100 mm nominal diameter. Pipelines used for export from production facilities may be larger in diameter, typically in the order of 100 mm to 200 mm or more. Pipelines and flowlines may be installed above or below ground. In the Cooper Basin, steel flowlines are usually located on supports above ground, to avoid corrosive soils.

All pipeline design and construction is undertaken in accordance with relevant Australian Standards, in particular:

AS 4041: Pressure Piping AS 2885: Pipelines – Gas and Liquid Petroleum.

Adherence to design standards minimises the risk of pipeline failure, which may have serious environmental implications in sensitive locations such as in floodplains or creek lines. Design standards which aim to protect pipeline integrity and prevent loss of hydrocarbons to the environment include:

design of the pipeline to have an appropriate diameter and wall thickness for the operating pressure requirements

specification of appropriate mitigation measures (as identified in a risk assessment of the pipeline) such as installation of heavier wall thickness pipe where it is buried under rivers, creeks and roadways

on floodplains and under creeks, it may be necessary to use welded lines and / or concrete weighting to counter the buoyancy of the pipeline when the soil is saturated with water

use of high integrity external coating and cathodic protection devices for buried steel pipe to protect against corrosion

aboveground pipelines must be supported to maintain them clear of corrosive soils installation of overpressure protection devices to prevent line rupture which may include

some or all of the following: o a high pressure shut down valve to isolate the well from the pipeline o a pressure safety valve (PSV) designed to relieve the pressure above design operating

pressure of the pipeline o liquid pipelines may be equipped with thermal PSVs and check valves to prevent line

rupture as a result of temperature induced expansion PSVs and pipeline bleed points are provided with sumps or drums of sufficient capacity to

contain discharged fluids if required, launching and receiving facilities for pipe cleaning devices (referred to as pigs)

are constructed to contain minor spills during removal/insertion of pigs and with a sump for draining the receiver/launcher prior to opening. Pigs are typically not used on flowlines due to their short length and pipe diameter.

3.4.1 Route Selection, Survey and Site Preparation

Surveys are undertaken and a preferred route alignment is selected according to evaluation criteria, such as constructability, environmental and cultural heritage sensitivity, safety and cost.

For buried pipelines, the right-of-way (ROW) is cleared with topsoil and vegetation stockpiled separately. The width of the right of way for a buried pipeline depends on the pipeline diameter, but is typically in the order of 15 – 30 m wide. Large diameter pipe may require a greater width to provide a safe construction area for personnel and equipment. Additional width may be required in some areas to allow room for laydown of pipe and equipment and to allow trucks and vehicles to pass locations



where construction is being carried out. Dune crossings may also require a greater width to be disturbed (e.g. up to 50 m or more for large dunes) to achieve sufficient depth of cover without the curvature of the pipe exceeding allowable limits, and to ensure access and construction activities can be carried out safely.

During construction of above ground pipelines the construction easement may be cleared but is not usually graded. Above ground pipelines often require a narrower easement and so result in reduced disturbance to vegetation and topsoil. Above ground pipelines and pipeline stations require ongoing control of vegetation to manage the risk of damage due to fire.

3.4.2 Pipeline Construction

Construction of a buried pipeline involves trenching or ploughing along the alignment after the construction easement is cleared. Trenching to a depth of two metres or more may be necessary in locations where lines pass through sand dunes, areas subject to inundation, wash out areas or under roads. Breaks are left in the trench to facilitate fauna movement across and out of the open trench.

Steel and GRE pipe is transported to the pipeline easement in sections and pipe is typically laid end-to-end adjacent to the trench on raised skids to protect the pipe coating from damage. This process is known as ‘pipe stringing’. In the case of above ground pipelines, sections of steel pipe are laid out on raised skids adjacent to the eventual pipeline supports.

Steel pipes are either screwed together (e.g. for smaller flowlines) or welded in lengths. Welds are subjected to non-destructive testing (NDT), including radiography, to test for construction defects and to comply with specifications. GRE pipes are typically joined by threaded joins with O-ring seals. Spoolable composite pipe joins typically use proprietary steel joiners.

The joined pipe sections are lowered into the trench or laid on the surface using sideboom tractors. Above ground pipelines are buried under roads, at river and channel crossings and on floodplains where required.

Spoolable composite pipe is supplied on large reels and is transported to locations along the alignment on a carousel located on a truck. Pipe is pulled off the carousel and placed in the trench.

Where necessary, soil and / or padding from approved borrow pits is placed into the trench to protect and stabilise the pipe. The trench is then backfilled and compacted with previously excavated trench spoil material.

3.4.3 Pipeline Testing

The integrity of pipelines is verified using hydrostatic testing conducted in accordance with AS 2885. During hydrostatic testing the pipeline is capped with test manifolds, filled with water and pressurised in accordance with the standard. During hydrostatic testing, large sections of the pipeline trench may be kept open to allow identification and repair of any leaks that are detected.

The use of biocides and chemicals with hydrostatic test water may be required under some circumstances to prevent internal corrosion of the pipeline. Hydrostatic test water may be sourced from existing water bores. Produced formation water may also be utilised as a water source provided that it is adequately treated with biocide to remove potential for bacterial contamination of the pipeline.

Disposal of hydrostatic test water which contains biocide and other chemicals may be into existing lined and fenced evaporation ponds, or to specifically constructed pits sited to prevent the contamination of surface or near surface waters. Hydrostatic test water that has no biocides or deleterious chemicals added is generally disposed of to the land surface, away from sensitive areas such as creeks.

3.4.4 Site Restoration

The easement is reinstated and restored as soon as possible after pipe laying and backfill. This involves removal of all construction generated refuse, re-contouring of the site, re-establishment of



natural drainage lines, bank restoration (if necessary), topsoil respreading and respreading of any cleared vegetation. Soil rills may be used, in suitable areas, as a physical protection measure for above ground pipelines.

3.4.5 Operation

Pipeline operation and maintenance provide for continued monitoring and safe operation of the pipeline, as outlined in AS 2885. Inspection and monitoring of pipelines are carried out and the operating procedures followed ensure that they are operated within their design capability.

3.5 Road Construction and Maintenance

The majority of roads throughout the Cooper Basin are constructed and maintained by Santos. Senex currently maintains approximately 500 km of access roads to production wells and facilities, some of which are also station tracks.

Where possible, existing roads, station tracks and exploration well access tracks are utilised and maintained. However it is expected that some road construction or upgrading and realignment will be required for access to future production operations. Within Regional Reserves the creation of new access tracks will be kept to a minimum and where appropriate disused roads will be rehabilitated at the conclusion of activities.

Once surveys are complete and a preferred road alignment is selected, a road is constructed according to the land system(s) it will pass through. In most cases the easement will be rolled or capping may be laid over the natural surface material (e.g. in gibber plains or where the terrain is naturally flat and susceptible to erosion when disturbed). Alternative road surface preparation methods may also be trialled and used with DSD approval. Table 4 provides information on the road construction methods applied to land systems in the Cooper Basin (Source: Santos 2003a).

Table 4: Road construction methods for land systems in the Cooper Basin (Santos, 2003a)

Construction Method Land system

Wetlands Floodplains Gibber Plains

Tablelands Dunefields Salt Lakes

Avoid construction on land system

Utilise naturally cleared areas

Avoid steep slopes

Weave road between trees and large shrubs

Clear and grade easement

Roll easement

Cap road surface with clay or similar borrow material

Culverts or similar devices installed on drainage line crossing

Road construction styles are assessed according to the amount of anticipated use as well as the environmental sensitivity of the area. Roadside borrow pits are used to source material for road fill. Erosion controls are implemented during and after construction and particular attention is given to flood and water flow areas. Culverts or other structures may be installed where required to ensure that surface water flows are not impeded by the road.



Following construction, rehabilitation is undertaken to ensure that surrounding surface drainage is restored and erosion control structures are installed in erosion prone areas.

Supplies of suitable construction material, such as gravel and soil, are usually extracted from sites referred to as borrow pits. Borrow pits are excavated to provide:

soft earth for trench backfilling rubble and clay for upgrading or constructing roads and maintenance of production facilities rubble and earth for the construction of above ground pipeline infrastructure.

Borrow pits vary considerably in dimension depending upon the quality and quantity of material contained in them.

Site selection, environmental management and restoration of borrow pits is undertaken in accordance with the SEO (Senex, 2016) and DSD GAS Criteria for the construction, management and rehabilitation of borrow pits

3 (DSD, 2014). Existing borrow pits are used in preference to new ones

where appropriate.

In the event that damage occurs to public roads as a result of Senex’s operations, maintenance activities will be undertaken to restore and maintain the road at an acceptable standard (as a minimum to pre-existing standard).

3.6 Aircraft Landing Area

Senex may, in the future, propose to construct aircraft landing areas near production facilities to enable personnel to be flown directly to Senex’s operational areas. This would achieve a reduction in overall travel times, avoidance of rain induced delays due to road closures and enable access to operational areas when road access is restricted by inundation from flood events.

The design specification for an aircraft landing area would meet the CASA Guidelines for Aeroplane Landing Areas (CASA, 1992) and standards published by the RFDS. This would be suitable for aeroplanes such as RFDS PC 12, Saab SF340B aircraft and light twin engine aircraft to land.

To meet CASA requirements, the compacted runway surface component would be approximately 1800 - 2000 m long and 20 m wide, with the runway strip and adjacent flyover areas (which must be clear of vegetation) totalling approximately 1320 m by 90 m. In addition to this, objects located within the approach and take-off areas and lateral transitional areas are not permitted to protrude above prescribed surface slopes. An apron (parking area) of approximately 100 m by 30 m with a 12 m wide taxiway to the runway would also be required.

The aircraft landing area would be primarily used in the daytime but it may be designed to be suitable for night-time helicopter use in case of emergencies.

The area would be fenced to exclude cattle. Gates and signage would also be installed to restrict vehicle and personnel movement through the landing strip area.

An aircraft landing area would be located in an area where earthworks and vegetation clearance requirements are limited (e.g. in a flat interdune swale).

3.7 Oil Transport

Oil from Senex’s production facilities is transported either by pipeline or tankers, to third party facilities in the Cooper Basin or to other facilities in South Australia or Queensland. There may be several tankers per day travelling from a facility along access roads and in some cases along public roads. Tanker load out areas at the facilities are lined and bunded to contain any spills and are operated in

3 Note: Borrow pits established prior to the introduction of the November 2014 GAS criteria (DSD, 2014) and are suspended (i.e.

not yet rehabilitated) may not achieve a 0, +1 or +2 score under the 2014 GAS criteria until immediately prior to license relinquishment. This should not be considered a non-compliance in the interim. Senex is seeking to undertake a review of existing borrow pits using a risk-based approach to identify borrow pits that are a priority for management.



accordance with the Australian Standard (AS) 1940:2004 and EPA ‘Liquid Storage - Bunding and Spill Management Guidelines Version 080/12’ (2012).

Access roads in the Cooper Basin may cross creek beds, including the Cooper and Strzelecki Creeks. These creeks are generally dry; the lower Cooper flows once every 2-5 years on average, and flows in the Strzelecki occur even less frequently.

Safe transportation of the oil from the well site to the delivery point is the prime responsibility of the transporters, under the Dangerous Substances Act 1979 and the Environment Protection Act 1993. However, under the Petroleum and Geothermal Energy Act 2000, Senex is responsible for minimising the impact of transportation spills of oil produced by Senex, and the cleanup and remediation of such spills, until the oil is accepted by the purchaser at the delivery point. Suitably trained, experienced and licensed contractors are used to transport oil.

3.8 Waste Management

Waste management is an important issue and Senex will continue to incorporate appropriate waste management practices into the construction, operation and abandonment phases of its developments.

Waste will be appropriately managed to avoid or minimise the potential for:

release of hazardous waste to land or waters through inappropriate waste disposal or accidental release;

inadequate waste management leading to inappropriate disposal or inadequate re-use and recycling; or

impacts to the environment, land use or wellbeing of people resulting from inappropriate waste disposal.

Senex will, where possible, follow the principles of Avoid, Reduce, Reuse, Recycle, Recover, Treat, Dispose and put measures in place to prevent pollution by reducing the use of energy, water, material resources, and recycling waste where possible.

Senex is responsible for the management of all the wastes it generates and for its disposal in accordance with regulatory requirements and industry standards. Waste from operations is generated from two main streams: operational waste and domestic waste (Table 5).

Table 5: Typical waste streams

Waste Type Disposal

Operations Waste

Gaseous waste Flared or vented – gas, CO2, H2S, CO

Generator and vehicle emissions

Produced formation water Interceptor pits and then to evaporation ponds

Waste oil / water (slops) hydrocarbon / water mixtures or emulsions

Directly skimmed from ponds and, where possible, returned to the production facilities for processing. Stored in a bunded area for collection and transport offsite by a licensed regulated waste contractor to a licensed regulated waste facility for treatment, recycling or disposal.

Pig-receiver / slug catcher scale Lime scale and sludge collected for transport offsite by a licensed regulated waste contractor to a licensed regulated waste facility for disposal.

Contaminated soil Soils contaminated with chemicals are to be managed as specified in the SDS for the spilt chemical.

Soils contaminated with hydrocarbons are to be treated insitu or collected and stored in the designated soil containment areas located at Senex sites.

Collected for transport offsite by a licensed regulated waste contractor to a licensed regulated waste facility for disposal.

Hydrotest water Recycled for each hydrotest section

Evaporation pond or to ground if complies with ANZECC and EPA criteria

Empty drums – plastic fuel, lubricant and chemical containers

Drums to be transported offsite by waste contractor for re-use, recycling or disposal



Waste Type Disposal

Chemical waste Stored in bunded areas in accordance with Australian Standards and EPA Bunding and Spill Management Guidelines for transport offsite by a licensed regulated waste contractor to a licensed regulated waste facility for recycling or disposal.

Plastic pond liner (e.g. HDPE) Transported to a licensed recycling facility (where possible) or sent for disposal at an appropriately licensed facility.

Metals – empty steel drums, bulk scrap steel, pipe, bolts, wire / cables, mini rings

Segregate (stored separately from other waste) metals from other wastes and store for recycling

Timber pallets (skids) Recycled where possible

Batteries Collected for transport offsite by a licensed regulated waste contractor to a licensed regulated waste facility for treatment, recycling or disposal.

Vehicle tyres Collected for transport offsite by a licensed regulated waste contractor to a licensed regulated waste facility for treatment, recycling or disposal.

Workshop waste – filters, rags, grease and lubricants

Recycle where possible and remainder for disposal to EPA licensed landfill

Oil and lubricants to be collected and stored in bunded areas awaiting transport offsite by a licensed regulated waste contractor to a licensed regulated waste facility for treatment, recycling or disposal

Domestic waste

Storm water runoff (camp) Runoff to vegetation

Sewage Treated at facility in septic tank or approved aerobic system (e.g. Envirocycle / Biocycle).

Treated water irrigated to land. Sludge and residue collected by a licensed contractor and disposed of at an appropriately licensed facility.

Grey water Treated at facility in Septic tank or approved aerobic system (e.g. Envirocycle / Biocycle. Treated liquid to irrigation or ponds.

General wastes – food waste, food wrappers, plastic bags, packaging

Securely stored in a covered bin (to prevent wildlife access) for regular removal to general landfill. Rubbish contained and controlled to minimise odours and maintain hygiene.

Comingled recyclable material – paper and cardboard, timber pallets, plastics and aluminium cans

Segregated and placed in bins or skips for recycling

Grease trap wastes Collected for transport offsite by a licensed regulated waste contractor to a licensed regulated waste facility for treatment, recycling or disposal.

3.8.1 Landfill – Domestic Waste

Senex does not currently operate landfill sites in South Australia and has no current plans to develop a landfill site. Any waste disposed to landfill is taken to appropriately licensed landfills (e.g. Moomba).

If Senex were to establish a landfill site all necessary approvals would be sought through the EPA and in consultation with DSD.

3.8.2 Sewage Waste Management

Sewage wastes at production facilities are disposed of using on-site systems that are managed in accordance with the South Australian Public Health (Wastewater) Regulations 2013 and in compliance with the South Australian Health On-site Wastewater Systems Code, or be to the satisfaction of the Department of Health. Consequently Senex will ensure compliance with Clause 17 of the Environment Protection (Water Quality) Policy 2015.

3.8.3 Contaminated Soil Treatment / Soil Remediation Areas

A suitable spill remediation method will be selected based on volume, estimated horizontal and vertical impact and the environmental sensitivity of the impacted environment. Minor spills in lined bunded areas are generally treated in situ in accordance with EPA guidelines. The main method of treatment and disposal of hydrocarbon contaminated soil outside of bunded areas is through insitu



treatment or removal to a Senex production facility for temporary storage in a designated bunded area. Contaminated soil that is unable to be remediated onsite will be transported by a licensed regulated waste contractor to a suitable EPA licensed landfill for treatment or disposal.

The assessment for uncontained spills with a larger scale impact (potentially non-trivial) will be undertaken in accordance with the National Environment Protection (Assessment of Site Contamination) Measure (1999) amended in 2013 and relevant SA EPA Guidelines.

Senex do not currently have a land treatment area for the bioremediation and treatment of hydrocarbon contaminated soils due to the low volumes generated. If required in the future, a land treatment site would be located away from watercourses, floodplains or areas of shallow groundwater. Establishment of a land treatment site would require approval by DSD and the EPA and would be undertaken in line with the relevant EPA guidelines, including the EPA Guideline “Environmental Management of On-site Remediation” 2008. The land treatment site would be designed taking into account a number of factors, including volume of contaminated soil, type of contamination, methodology, active ingredient, pre and post treatment concentrations, base liner design (to ensure permeability) and re-use options on-site.

3.9 Decommissioning / Rehabilitation

Senex will progressively rehabilitate facilities that are no longer required (for example, disused roads, facilities, pipeline routes and borrow pits). The rehabilitation of these sites will include:

removal of all above-ground infrastructure and rubbish testing for contamination of soil and groundwater (and remediating sites to the relevant

regulated standard) re-contouring land surfaces to reinstate natural contours and drainage lines ripping compacted areas (except in gibber systems) to alleviate compaction and encourage

revegetation.

Site-specific procedures apply to some facilities. For example, oil pipelines are pigged to remove residual hydrocarbons or sludge, and for buried pipelines, aboveground points are cut off and blinded below the surface.

Detailed plans for decommissioning and rehabilitation would be prepared prior to the operations being undertaken. Plans would be developed in consultation with DSD and relevant stakeholders.



4 Existing Environment

The Cooper Basin covers a total area of 130,000 km2 of which approximately 50,000 km

2 lies within

north-eastern South Australia.

The natural environment of the Cooper Basin has been extensively detailed in several previous EIRs including the Santos Production and Processing EIR (Santos 2003a; 2010); Beach Petroleum Production Operations EIR (Beach, 2009); Senex PEL182 Controlled Access Zone Drilling EIR (Senex, 2016a); and the Senex PEL182 Geophysical Operations EIR (Senex, 2013). These EIRs have detailed the following aspects of the Cooper Basin environment:

climate soils and landform hydrology flora and fauna geology and hydrogeology aquifer use Aboriginal and non-Aboriginal heritage land use socio-economic environment.

This section provides an overview of the environment of the Cooper Basin, however information presented in the EIRs mentioned above is generally not repeated in detail in this document.

4.1 PEL182 Existing Environment

PEL182 covers an area of approximately 1,750 km2, with the Controlled Access Zone (CAZ) constituting

approximately 245 km2 (see Figure 8 to Figure 9). PEL182 contains a diverse landscape including ephemeral

Cooper Creek floodplains and large ephemeral to semi-permanent water bodies such as lakes and waterholes that interface with extensive dune fields. Vegetation communities range from open tall woodlands on drainage lines to densely vegetated swamps containing low shrubs, and tall open shrublands over grasslands on sand dunes to low grasslands and forblands on the flood outs, claypans and lakes.

4.2 Climate

The region has an arid climate, with low average rainfall and high evaporation. Seasons are generally characterised by hot dry summers and mild dry winters. Rainfall in the area is highly erratic, with the annual average being about 100 to 200 mm however the annual rainfall can be recorded in one event (Arid Areas Catchment Water Management Board 2006). There is no distinct seasonal rainfall pattern and rainfall is often associated with thunderstorm activity and as a consequence can be localised and intense.

A current summary of climate records for Moomba Airport (Station 017123; BOM 2016) is provided in Table 6.

Table 6: Temperature and rainfall records for Moomba (1995-2016)

J F M A M J J A S O N D Annual

Mean Daily Max (°C) 38.6 37.0 33.9 29.3 23.9 19.9 19.6 22.7 27.6 30.9 34.2 36.5 29.5

Mean Daily Min (°C) 24.5 23.6 20.4 15.6 10.8 7.5 6.3 8.0 12.2 15.8 19.6 22.2 15.5

Mean Rainfall (mm) 14.7 29.8 22.2 7.3 10.9 11.2 14.5 4.7 12.3 9.3 20.1 13.6 172.8

Median Rainfall (mm) 3.4 10.2 2.2 1.0 3.2 5.6 1.3 0.7 0.8 3.0 7.2 6.2 157.6

4.3 Landforms and Land Systems

Six major landforms are found in the Cooper Basin. Table 7 provides a brief description of the Cooper Basin landforms and key environmental issues. Further details are provided in Santos (2003a; 2010).



The distribution of these landforms across the Cooper Basin and accompanying photographic examples is shown in Figure 7.

A number of named land systems4 have been mapped across the Cooper Basin as part of broader

land system mapping in the pastoral areas of South Australia (Marree SCB 2004). These land systems and their soil and vegetation characteristics are summarised in Appendix 1. Table 7 correlates the landforms found in the Cooper Basin with the land systems in which they occur.

The sensitivity of each landform to disturbance depends upon its basic characteristics of geology, topography, soils, hydrology, flora and fauna. These sensitivities are outlined in this EIR in Table 19 in Section 5.5 and each landform is discussed in detail with respect to these characteristics in Santos (2003a; 2010) and Senex (2013; 2016a).

4.3.1 PEL182 Landforms, Landsystems and Soils

PEL182 is dominated by the Cooper land system, and the licence area also extends across minor components of several other land systems including the Hope, Ketietoonga and Koonchera land systems (see Figure 8 and Table 7).

The CAZ area is dominated by the Cooper land system and a minor component of the Hope land system occurs in the north-west corner (see Figure 8). These land systems are generally characterised by dune fields with expansive parallel sand ridges and areas of floodplains and floodouts, which can be differentiated on the basis of frequency and intensity of flooding. PEL182 contains examples of most land units of the Cooper land system.

PEL182 does not include the Coongie Lakes themselves, but it does include several ephemeral lakes associated with the Cooper Creek system, as well as the Cooper Creek Main Channel, and a small section of the North-West Branch (see Figure 8). Extensive areas of floodplain are present.

The Controlled Access Zone (CAZ) and the area of Walk In Zone in the south-west of PEL 182 are dominated by channels and floodplains of the Cooper land system (see Figure 9). The Walk In Zone surrounding the Coongie Lakes National Park and No Go Zone contain predominantly sand dunes of the Cooper land system, with some areas of floodplain and ephemeral lakes.

Sand dunes dominate a large part of PEL182; including much of the Cooper land system. They generally vary from red siliceous sands to whitish siliceous sands. The red dunes are older, and may have a clayey core. Pale dunes are more recent depositions from the floodplains, and are more mobile.

The floodplain soils within the CAZ generally consist of pale grey sandy to silty clays with large areas of “crab holing” and self-mulching clays. The dunefields that adjoin the CAZ generally comprise of 10-15m high pale yellow siliceous dunes with low clay content and mobile crests. Interdunes vary from perched sandy swales to exposures of underlying brown or grey former floodplain or lacustrine clays.

The Hope land system occurs on the outskirts of the Cooper system in the north-western section of PEL182 and intersects the northern part of the CAZ. Land units within this part of PEL182 are typical of this land system, with long parallel sand dunes of red, yellow or white aeolian sands, clayey interdunes and numerous claypans and internal soakages and flood out areas.

Table 7: Cooper Basin landforms and descriptions

Landform Land system Description

Dunefields

Bloodwood, Collina, Cooper, Diamantina, Eulpa, Hope, Jeljendi, Ketitoonga, Koonchera, Marqualpie, Mulligan, Simpson. Strzelecki, Tingana, Tirari, Warburton, Wirringina

Generally parallel dunes of red or yellow sands of height 5 – 20 m separated by flat interdune corridors which are often sandy, but due to limited drainage also often contain claypans. In inter-dune corridors where infiltration is limited salt lakes are sometimes present. In the Cooper Basin the dunes trend approximately north-south.

Soils are red-yellow-siliceous sands on the dunes and red massive earths or grey self-mulching clays in the swales.

Floodplains

Cooper, Diamantina, Kachumba, Mulligan, Tirari, Warburton

The extensive flood-out areas adjacent to Cooper Creek, Strzelecki Creek, Wilson River and the Diamantina River. The floodplains are periodically inundated when the creeks and rivers overflow their banks.

4 Land systems are areas throughout which there is a recurring pattern of geology, topography, soils and

vegetation.



Landform Land system Description

They are characterised by grey sediments which are deposited on the plains by floodwaters. In places, dunes are either co-dominant or occasionally present.

Soils are grey self-mulching cracking clays and pale sandy clays.

Wetlands

Cooper, Diamantina, Mulligan The channels, waterholes, swamps and lakes associated with Cooper Creek, Strzelecki Creek, Wilson River and Diamantina River. Some of the waterholes always contain water, but the channels, swamps, and lakes are frequently dry. They are located on or close to the main watercourses and are therefore inundated more frequently than the surrounding floodplain.

Soils are predominantly grey self-mulching cracking clays.

Salt lakes

Blanche, Collina, Wirringina (Note: Small salt lakes are also present in many dunefield land systems)

Terminal lakes or pans of varying sizes where evaporation has resulted in the concentration of soluble salts as a surface crust. They are periodically inundated, but are usually dry.

Soils are salty overlying grey self-mulching cracking clays.

Tablelands

Lamamour, Merninie, Mumpie, Sturts

Uplifted and eroded gibber plains that have resulted in the formation of low but steep silcrete capped hills, escarpments and mesas and extensive gibber covered footslopes.

The tablelands are separated by undulating gibber plains. The highly polished stones or gibbers are usually embedded in a clayey crust, thereby protecting the underlying soil from erosion.

Soils are crusty red duplex soils and brown self-mulching cracking clays on the slopes. Soils on the plains are reddish powdery calcareous loams.

Gibber plains

Bloodwood, Koonchera, Lamamour, Merninie, Sturts

An undulating stony plain, sometimes with the occasional small dune or small silcrete capped mesa. The highly polished stones or gibbers are usually embedded in a clayey crust, thereby protecting the underlying soil from erosion.

Soils are crusty red duplex soils.

Source: PIRSA



Figure 7: Cooper Basin Landforms (Source: RPS)



Figure 8: Satellite Image of PEL182 with Land systems and Special Management Zones

Figure 9: Satellite Image of PEL182 South-Western Corner



Senex’s current production facilities are located predominantly in dunefield and floodplain land systems. The location of current Senex production facilities and the relevant landforms and land systems are set out in Table 8.

Table 8: Current Senex production facility locations and relevant landforms and land systems

Field / Facility Licence Landform Land system

Acrasia PPL 203 Gibber plains / tablelands Merninie

Burruna PPL 251 Dunefield Tingana

Growler PPL 242 Dunefield /Floodplain Cooper

Harpoono PPL 209 Dunefield Tingana

Martlet PRL137 Floodplain Cooper

Mirage PPL 213 Dunefield Tingana

Mustang PPL 243 Dunefield Cooper

Padulla PPL 221 Dunefield Hope

Snatcher PPL 240 Dunefield / floodplain Cooper

Spitfire PPL 258 Dunefield / floodplain Cooper

Vanessa (operation pending) PRL135 Dunefield Cooper

Ventura PPL 214 Dunefield Tingana

Vintage Crop PPL 241 Dunefield Tingana

Worrior PPL 207 Dunefield Hope

4.4 Flora and Fauna

4.4.1 Flora

The vegetation characteristics of the landforms in the Cooper Basin are outlined briefly in Table 9 and are described for each named land system in Appendix 1. Further detail is also provided in Santos (2003a; 2010) and Senex (2013; 2016a).

Table 9: Typical vegetation characteristics of landforms in the Cooper Basin

Landform Typical Vegetation Characteristics

Dunefields

Vegetation on dunes includes herbs and ephemeral herbs on dune crests, open shrublands of sandhill wattle, whitewood or hakea and hummock grassland of spinifex and sandhill canegrass.

Vegetation in interdune areas is largely dependent on dune spacing and may consist of hummock grassland, chenopod shrubland, open shrubland or low open woodland.

Floodplains

Major intermittent watercourses are characterised by woodlands of river red gum, coolibah or gidgee with a tall shrub layer fringing the floodplains, channels and semi-permanent waterholes.

Open coolibah woodland and with an understorey of lignum, chenopod shrubland and grasses is common in frequently flooded areas with outer floodplain areas often consisting of open shrubland. Groundcover on floodplains has a high ephemeral content.

Wetlands

Vegetation similar to floodplains is present, with open woodlands of river red gum or coolibah with an understorey of lignum and chenopod shrubland typically bordering the margins of wetland areas.

Salt lakes

Immediate surrounds usually fringed with samphire grading to low open chenopod shrubland in the outer surrounds.

Tablelands

Low open woodlands, shrublands and low open chenopod shrublands, with more heavily wooded areas of mulga, red mulga and gidgee along drainage lines and more permanent waterholes.

Gibber plains

Vegetation ranges from relatively dense low open shrubland to naturally bare tussock grasslands, or short-lived copperburrs and ephemeral grasses. Low woodland of gidgee and mulga on drainage lines.



4.4.2 Fauna

Terrestrial and avian fauna species present in the Cooper Basin include:

Mammals: Small mammals such as Fat-tailed and Stripe-faced Dunnarts, Giles Planigale, Sandy Inland Mouse and House Mouse are common. Other mammals present include Little Broad-nosed Bat, and Short-beaked Echidna. Larger mammal species include the Red Kangaroo, Dingo, and non-native species Cattle, Cat, European Rabbit and Fox.

Reptiles: Common reptiles include Fat-tailed Gecko, Eastern Brown Snake, Sand Goanna, Gidgee Skink, Painted Dragon, Mulga Snake, Curl Snake and Inland Taipan.

Amphibians: Ten frog species have been recorded in the Cooper Creek system including several species of burrowing frog (e.g. Trilling Frog, Water-holding Frog) which may be relatively widespread and others (Desert Froglet, Green Tree Frog, Broad-palmed Frog) that would be restricted to areas near water (i.e. the Cooper Creek) except during flooding.

Birds: Bird species present include Australian Magpie, Galah, Brown Falcon, Budgerigar, Black-faced Woodswallow and Little Corella. The area also supports a diverse assemblage of waterbirds, as discussed below.

In dry periods, aquatic fauna are concentrated in refuges such as Coongie Lakes and the permanent waterholes on the upstream reaches of the Cooper in South Australia. During flooding, these fauna increase rapidly in abundance and occur across the vast area of channels, waterholes, swamps and floodplains in the Cooper Creek system.

The wetlands associated with the North West Branch of the Cooper Creek, including Coongie Lakes, are recognised as a region of exceptional ecological value. The Cooper Creek system supports a diverse range of aquatic fauna including waterbirds, fish, frogs and aquatic invertebrates. Wetland species recorded in the area include 74 waterbird species and 11 other wetland dependent species. The Coongie Lakes area also supports a major assemblage of raptors and forms a key area for raptor breeding. Researchers have recorded 20 native mammal species, 36 reptile species and 10 frog species in the region (DEHAA 1998; 1999).

The Coongie Lakes wetlands have been recognised as internationally significant under the Ramsar Convention, providing a feeding, resting and breeding site for large numbers of migratory and nomadic birds. The most abundant species during flooding include Grey Teal, Pink-eared Duck, Wood Duck, Australian Pelican, Great Cormorant, Black Swan, Eurasian Coot, Black-tailed Native-hen, and Red-necked Avocet. The Cooper Creek system (particularly areas such as Coongie Lakes) also supports rare or threatened waterbird species such as Freckled Duck, Musk Duck, Little Egret and Intermediate Egret (DEHAA 1998; 1999).

The most significant waterbird feeding, nesting and breeding areas are located outside PEL182 (within the Coongie Lakes National Park and No Go Zone), however these species and the Cooper Creek’s aquatic fauna become widespread during large floods when vast areas are inundated. During periods of drought, most species reliant on aquatic habitats are concentrated in refuges such as Coongie Lakes and permanent waterholes.

The aquatic invertebrate fauna is abundant and diverse and includes an array of insects, crustaceans and gastropods (Reid and Puckridge 1990). Aquatic vertebrates include Desert Rainbow Fish, Water Rat, Macquarie Tortoise and a diverse frog population. The fish community of the north-west Cooper Creek system is one of the most significant in South Australia as it is close to its original composition, with only two exotic species present (Reid and Puckridge 1990). Two species of fish, the Lake Eyre Callop and Cooper Creek Tandan, are endemic to the Cooper Creek catchment.

Other terrestrial and avian fauna species likely to be present in the PEL182 area include:

Mammals: Small mammals such as Fat-tailed and Stripe-faced Dunnarts, Giles Planigale, Sandy Inland Mouse and House Mouse are common. Other mammals present include Little Broad-nosed Bat, and Short-beaked Echidna. Larger mammal species include the Red Kangaroo, Dingo, and non-native species Cattle, Cat, Pig, European Rabbit and Fox.

Reptiles: Common reptiles include Fat-tailed Gecko, Eastern Brown Snake, Sand Goanna, Gidgee Skink, Painted Dragon, Mulga Snake, Curl Snake and Inland Taipan.



Amphibians: Ten frog species have been recorded in the Cooper Creek system including several species of burrowing frog (e.g. Trilling Frog, Water-holding Frog) which may be relatively widespread and others (Desert Froglet, Green Tree Frog, Broad-palmed Frog) that would be restricted to areas near water (i.e. the Cooper Creek) except during flooding.

Birds: Bird species present include Australian Magpie, Galah, Brown Falcon, Budgerigar, Black-faced Woodswallow and Little Corella.

4.4.3 Threatened Species and Communities

A number of species listed under Commonwealth (Environment Protection and Biodiversity Conservation Act 1999) and State (National Parks and Wildlife Act 1972) legislation are known to occur in the Cooper Basin. Listed rare or threatened species that have been recorded or predicted to occur in the region are listed in Appendix 2 and are further discussed in detail in Senex (2013; 2016a).

No nationally significant threatened ecological communities have been identified in the PEL182 region through EPBC Act database searches or previous field inspections.

One threatened ecological community listed under the EPBC Act occurs in the broader region – the community of native species dependent on natural discharge of groundwater from the Great Artesian Basin. This community occurs at Great Artesian Basin (GAB) springs, which are located beyond the margins of the Cooper Basin.

Three vegetation communities that potentially occur within the area are listed as ‘of concern’ in the listing of threatened ecosystems of the Non-Agricultural Region in South Australia (Neagle 2003; DEH Provisional list 2005). They are generally at threat from introduced herbivore grazing which removes vegetation and changes plant species composition. These communities are:

Eucalyptus coolabah ssp. arida (Coolibah) Woodland on levees and channel banks of regularly inundated floodplains

Atriplex nummularia (Old-man Saltbush) Open Shrubland with occasional emergent Eucalyptus camaldulensis (River Red Gum) or E. coolabah ssp. arida (Coolibah) on low sandy rise of floodplains

Chenopodium auricomum (Golden Goosefoot) Shrubland on cracking clay depressions subject to periodic waterlogging.

Senex is confident that significant impacts to listed threatened species, communities and migratory species that are likely to occur in the Cooper Basin region can be avoided, due to the nature and limited area of production activities and the management measures that are implemented. Site specific assessments are carried out for all sites prior to commencement of operations (as discussed in Section 2.1.1) to ensure that any potential impacts are identified and are minimised or avoided.

4.4.4 Coongie Lakes Ramsar Wetland and EPBC Act

The Coongie Lakes wetlands have been recognised as internationally significant under the Ramsar Convention, providing a feeding, resting and breeding site for large numbers of migratory and nomadic birds. PEL182 is located within the Ramsar area defined by the Ramsar ‘triangle’ that extends from the Queensland border to the vicinity of Lake Hope but it does not intrude on the Coongie Lakes NP or Coongie Lakes proper. The designated Coongie Lakes Ramsar wetland site is a large area that includes extensive areas of dune field and gibber tablelands with little or no hydrological connection to the Cooper Creek in addition to the channels, waterholes and floodplains of the Cooper Creek system. Hundreds of petroleum wells and several oil and gas facilities are currently located within the designated Ramsar area.

The numerous migratory bird species that are listed under international agreements and protected under the EPBC Act that may use Cooper Creek floodout areas (when inundated) are not likely to be significantly impacted by production operations in PEL182 as the Coongie Lakes National Park, No Go Zone and Walk In Zone buffer the habitats in the Coongie Lakes from disturbance. The overall impact on available habitat is expected to be limited to generally small-scale short-term disturbance e.g. well sites, access tracks, buried pipelines and production facilities located in elevated environments outside of areas subject to inundation.

As discussed in Section 2.2, it is not expected that production operations within PEL182 will trigger any of the criteria that would require EPBC Act approval; however Senex will continue to assess the potential site specific



impacts of proposed production operations against the relevant EPBC Act significance criteria to ensure this assessment remains valid.

4.4.5 Introduced Pest Plants and Animals

Introduced plant species recorded in databases as occurring in the region include:

Buffel Grass (Cenchrus ciliaris)

Mexican Poppy (Argemone ochroleuca ssp. ochroleuca)

Mimosa Bush (Acacia farnesiana)

Common Verbena (Verbena officinalis)

Creeping Heliotrope (Heliotropium supinum)

Wild Turnip (Brassica tournefortii)

Common Sow-thistle (Sonchus oleraceus)

Black Nightshade (Solanum nigrum)

Wandering Speedwell (Veronica peregrine ssp. xalapensis)

Caltrop (Tribulus terrestris)

Colocynth (Citrullus colocynthis)

Grain Sorghum (Sorghum bicolor)

The density of weed species is generally relatively low, and the majority of the introduced plants known to occur in the Cooper Basin are naturalised or widespread species of limited concern to the environmental or pastoral values of the region. Invasive species of particular concern include Buffel Grass and Noogoora Burr. Mexican poppy (Argemone ochroleuca) and Couch grass (Cynodon dactylon) have created localised weed problems, outcompeting native species and reducing habitat (DEWNR 2014).

Invasive species of concern that occur in PEL182 include Buffel Grass, Mexican Poppy and Mimosa Bush. Noogoora Burr (Xanthium strumarium) is another invasive weed of concern to the region (it was recorded in drainage channels to the west of PEL182 in 2010), but it has not been recorded within PEL182. Recent weed surveys of the area are limited, and there is some potential that it may be present.

Pest animals that have been identified by recent surveys to occur in the region include feral cats and foxes, feral pigs, rabbits, donkeys, horses and camels.

4.5 Surface Water

Wetland and Floodplain Land Systems

The Cooper Creek system is the dominant surface water feature in the region. The Cooper Creek originates in catchments in south-west Queensland. During periods of low flow, most water flows through the North-West Branch of the Cooper Creek into the Ramsar-listed Coongie Lakes and Lake Goyder. If flows are large enough to fill these lakes, additional water flows down the main branch of the Cooper towards Lake Hope and eventually discharges into Lake Eyre. The main channel of the Cooper Creek is generally well defined and connects a series of ephemeral swamps and permanent and semi-permanent waterholes.

Significant local rainfall events can also result in shallow inundation of floodplains, inter-dune claypans and other areas of poorly drained impermeable soil, which can persist for days to weeks or longer. Local rainfall and run-off also results in flow in ephemeral watercourses, most of which drain into either the Cooper or Strzelecki Creeks.

Cooper Creek flows are unregulated and extremely variable. Flow occurs in one or more discrete pulses each year and several months may pass without flow (Puckridge et al. 1999). Flow in the Cooper Creek occurs in almost every year, and in most years it reaches the Coongie Lakes (DEH 2008a).



The mean annual flow in the Cooper Creek is in the order of 1.4 million megalitres, with a median annual flow (at Cullyamurra Waterhole, near Innamincka) of 399,100 ML (NRW 2007, DWLBC 2007). The highest annual flow was over 14 million megalitres in 1974. Flow can occur in any month, and zero flows have also been recorded in all months of the year. It has been estimated that there is a 98% chance that flow rates will exceed 1m³/s at Innamincka each year (Kotwicki 1986).

During periods of high flow, floodwaters overtop the banks of the Cooper and flow southwards down the Strzelecki and Ooranie Creeks. Cooper Creek floods that are large enough to flow into Strzelecki Creek and its floodplain are relatively rare events. Previous investigations have estimated that floods of this size have an average frequency of approximately one in ten years (Puckridge et al. 1999). Flows into Ooranie Creek are more frequent, with an average frequency in the order of 1 in 5 years (SEA 1992, Puckridge et al. 1999). Table 6 outlines the frequency and extent of flow classes in the Cooper Creek that have been derived from the gauging station at Cullyamurra Waterhole, upstream of Innamincka.

Strzelecki Creek is predominantly dry. It can receive some localised inflow from heavy rainfall events but generally only flows during very large Cooper Creek floods, when water flows southwards from Innamincka towards Lake Blanche (a distance of approximately 200 km).

During very large floods, much of the floodplain area within the Cooper land system becomes inundated. However, within this land system, there are areas of dunefield, isolated sand dunes and patches of higher ground that are not subject to flooding.

PEL182 and Controlled Access Zone:

The Cooper Creek and Christmas Creek are the two main watercourses that occur within PEL182, along with a mosaic of minor channels, ephemeral lakes, floodplains and floodouts.

Upstream of PEL182, the Cooper Creek diverges into two separate branches. These branches consist of the North West Branch, which flows through Tirrawarra Swamp and then into the Coongie Lakes, and the Main Branch, which continues generally westwards along a diffuse course. During periods of low flow, most water flows through the North West Branch into the Coongie Lakes. If flows are large enough to fill these lakes, additional water flows through the main branch of the Cooper towards Lake Hope and eventually discharges into Lake Eyre.

Waters overflowing from the Coongie Lakes flow either south-west (through the Northern Overflow of Cooper Creek) or south along Christmas Creek, and reconnect with the main course of Cooper Creek leading to the downstream Kanowana Wetlands (Gillen and Drewien, 1993).

PEL182 contains sections of the Cooper Creek Main Branch and North West Branch. A section of the Main Branch is included in the CAZ and WIZ in the south-west of the PEL (see Figure 9). Christmas Creek is located within the CAZ.

Numerous waterholes occur along Christmas Creek and the branches of the Cooper Creek in PEL182. Salinity of waterholes varies in relation to time since flooding and salt input from saline alluvium or local springs.

PEL182 does not include the Coongie Lakes proper, but it does include some ephemeral lakes associated with the Cooper Creek system. The lakes within the PEL would receive flows of water from the Cooper Creek in years of higher flow, but would dry out almost entirely in extended drought periods. The WIZ intersects the western margin of Tirrawarra Swamp, which is located on the North West Branch of Cooper Creek. This swamp receives flows almost every year.

Coongie Lakes Ramsar Wetland:

The Coongie Lakes and the Strzelecki wetland systems are included in the directory of nationally important wetlands. The Coongie Lake system is also listed under the Ramsar Convention as a Wetland of International Importance, in recognition of its important role in providing refuge for the conservation of migratory and nomadic birds (Morton et al.1995, Blackley et al. 1996).

The Coongie Lakes Ramsar wetland covers the floodplain, lake and channel system of the upper Cooper Creek in South Australia, as well as large areas of dunefield with no hydrological connection to Coongie Lakes or the Cooper Creek (see Figure). It is estimated that the Coongie Lakes Wetlands Ramsar area covers 30% of the known oil and gas resources within the South Australian portion of the Cooper Basin (DEHAA 1999). The



Coongie Lakes National Park situated within the Coongie Lakes Ramsar wetland forms the core of the extensive Coongie Lakes system of wetlands and near-permanent freshwater lakes.

Dunefield Land Systems

Dunefields are extremely arid, lacking any permanent surface water with significant drainage lines generally absent. Surface water catchments are typically restricted to individual interdune corridors. Surface water ponds in interdune corridors, often collecting in claypans and occasionally salt lakes within the interdune. Infiltration rates are generally low, and surface water may remain in the swales and claypans for a few days to a few weeks or more, depending on the rainfall event and rates of evaporation.

Tableland and Gibber Plain Land Systems

Permanent surface water is scarce in the elevated areas of the tablelands and on the gibber plains, however temporary pools of water often form after rain in gilgais and low depressions. Networks of small, defined drainage lines (which can contain permanent waterholes) typically flow for only a short time (e.g. six to twelve hours) after rainfall has ceased and carry runoff from larger rainfall events.

Salt Lakes

Salt lakes are predominantly dry, but are occasionally filled by floodwaters from the major river systems. During flooding, water may remain fresh and can support abundant fish populations. Lakes become increasingly saline as they dry. The frequency of flooding and inundation is highly variable.

4.6 Geology

This section provides a brief description of the geology of the Cooper Basin. Further details are provided in Santos (2003a; 2010).

The Eromanga and Cooper Basins are located in central and eastern Australia. The Cooper Basin is a north-east, south-west trending basin that extends over an area of about 153,000 km

2 in north-east

South Australia and south-west Queensland (Stanmore 1989). It is unconformably overlain by the Eromanga Basin. The saucer-shaped Eromanga Basin extends over a much larger area of around one million square kilometres in Queensland, New South Wales, South Australia, and the south-east of the Northern Territory. The Eromanga Basin is overlain by the Lake Eyre Basin.

In the north-east of South Australia, the Lake Eyre Basin consists of surface sediments on floodplains, wetlands, tablelands, gibbers, salt pans. At depth, units include the Yandruwantha Sand (medium to coarse grained sand), the Namba Formation (deltaic and lacustrine clay, silt and sand), and the Eyre Formation (sandstone and shale). The thickness of Lake Eyre Basin sediments in the Moomba area is generally in the range 200 – 300 m (Drexel and Preiss 1995).

Below the Lake Eyre Basin section lie the Eromanga Basin sediments which are between 1200 m and 2,700 m thick (Gallagher and Lambeck 1989). These sediments were deposited under fluvial (river), lacustrine (lake) and later shallow-marine conditions, and are broadly continuous across the basin (Vine 1976). These sediments are gently folded in some areas and contain a succession of geographically extensive sandstone formations that serve as oil reservoirs and regional aquifers known as the Great Artesian Basin.

Located underneath the Eromanga Basin section, the total Cooper Basin sediment accumulations exceed 1,500 m in some places and are characterized by fluvial, deltaic, and swamp deposits that include some coal measures (Thornton 1979). These sediments contain petroleum reservoirs (mainly gas) and aquifers.

The tectonic history of the Cooper and Eromanga Basins is complex and has been characterised by several periods of rift-related subsidence and compressional uplift and erosion. This history has resulted in the Cooper Basin being subdivided into a number of large scale sub-troughs separated by fault bounded ridges. The historical evolution of the Cooper and Eromanga Basins is discussed by Kuang (1985), Finlayson et al. (1988), Gallagher (1988), Hunt et al. (1989) and Stanmore (1989). The Cooper and Eromanga Basins are currently subject to a regionally compressive stress regime. Motion



along fault bounded basement blocks results in strong local stress variations. Evidence from well bore geomechanics shows that conditions for movement on faults are present and that the structural evolution of the area is ongoing.

4.7 Hydrogeology

This section provides a brief description of the hydrogeology of the Cooper Basin based on information provided in Santos (2003a; 2010) and Beach (2012a).

Regional hydrogeology is dominated by the presence of the Great Artesian Basin, one of the largest multi-layer aquifer systems in the world. The Great Artesian Basin (GAB) comprises Jurassic and Cretaceous sediments of three large sedimentary basins, the Eromanga, Carpentaria and Surat Basins, of which the Eromanga Basin is the largest and most central. Only the south-western third of the Eromanga Basin extends into South Australia, with the Carpentaria and Surat Basins located in Queensland.

The groundwater flow in the GAB is generally to the south-west; with recharge occurring in northern Queensland and groundwater discharging as spring flow around Lake Eyre. Groundwater travel times can be of the order of 1 to 2 million years. In South Australia recharge also occurs along the western basin margin and a component of groundwater flow also comes from the eastern extension of the basin in New South Wales.

Throughout the GAB there are numerous permeable formations and a number of aquifers of regional significance. In central Australia the GAB sediments are overlain by the sediments of the Lake Eyre Basin. These sediments consist of Tertiary sands and often contain beds of lignite and clay. The sand units can host useful local aquifers that are often exploited for stock water. Localised aquifers can also be found in Quaternary alluvial sands and gravel. Depending on the location in the landscape, groundwater salinity in these shallow aquifers can range from fresh to saline.

Within the Eromanga Basin itself two major regional aquifer systems are identified, these being the Cadna-owie Formation and Algebuckina Sandstone (Cadna-owie–Algebuckina aquifer), and the upper confined aquifer consisting of sediments of the Winton and Mackunda Formations. The two aquifer systems are separated by the shales of the Bulldog Shale and Oodnadatta Formation. Aquifers of the Winton and Mackunda Formations are generally confined by clays and shale of the Winton Formation and Tertiary sediments of the Lake Eyre Basin. Both aquifer systems can be unconfined near the basin margins.

An intermediate aquifer exists between these two major aquifer systems and is hosted in the Coorikiana Sandstone, which forms a discrete aquifer of high salinity and low permeability in the southern and western Eromanga Basin. Although artesian pressures have been recorded in this aquifer it is generally not exploited due to its poor water quality and low yield. The Winton and Mackunda Formations, while generally confined, are not artesian and are not as widely utilised as the deeper and better quality artesian aquifers of the Cadna-owie–Algebuckina aquifer system.

The Cadna-owie–Algebuckina aquifer comprises the major source of groundwater in the Far North Prescribed Wells Area. To the east of the Birdsville Track Ridge, and overlying the Cooper Basin, the Cadna-owie–Algebuckina aquifer includes sediments of the Murta Formation and the Namur, Adori, Hutton and Poolowanna Sandstones. West of the Birdsville Track Ridge, the confining beds separating these sandstone units pinch out over the ridge and the individual sandstones merge into the Algebuckina Sandstone.

In various locations across the Cooper Basin, erosion of the Cooper Basin sediments and deposition of Eromanga Basin sediments over the top has resulted in contact or mixing between the two formations. As a result, over geologic time, hydrocarbons have migrated from the Cooper Basin into the Eromanga Basin. Indications of trace oil and gas are seen in the Jurassic (GAB) aquifers during drilling across the Cooper Basin because of this migration and in certain areas of the basin, the Eromanga Basin sediments (i.e. the GAB aquifers) are targets for oil exploration and production.



4.8 Social Environment

4.8.1 Aboriginal Cultural Heritage

The Cooper Basin region is culturally significant to the traditional Aboriginal owners. The Cooper Creek region (including the channels and lake shores of the North West Branch of the Cooper Creek and Coongie Lakes) were an important focus of Aboriginal occupation. Evidence of long term occupation includes rock art, burial sites, trade and ceremonial sites scattered with grinding stones and other artefacts associated with habitation.

Aboriginal sites can still be identified throughout the region and include features of spiritual importance and archaeological sites: for example middens, artefact scatters, rock engravings, arrangement sites, burial sites and quarries (Blackley et al. 1996). The Cooper Creek region has been proclaimed a State Heritage Reserve because of its association with Aboriginal and European history as well as its environmental significance. This area encompasses Innamincka and a one kilometre section either side of Cooper Creek, totalling 120km

2. It is rich in Aboriginal objects, campsites, quarries and

engravings with several unique designs located around Cullyamurra waterhole.

Table 10 summarises the land systems and the archaeological sites and artefacts which may be associated with them.

Table 10: Land systems and sites of Aboriginal artefacts

Land types Artefacts and sites Location of Sites

Sand dunes Burial sites: common Often in eroding sand dunes

Shell middens: common Near sources of permanent water such as Cooper Creek and Coongie Lakes

Flooplains, Wetlands, Salt Lakes Burial sites Isolated dunes and sandy rises

Campsites Isolated dunes and sandy rises

Shell middens Near lakes and rivers

Rock Art Near lakes and rivers

Tree scars: rare Along rivers and creeks

Tablelands and Gibber Plains Stone artefact scatters Near lakes and rivers

Cleared pathways Near stone arrangements

Stone tool quarries Mesa caps

Stone arrangements Gibber country

Source: Santos (2003a)

Prior to any works being undertaken on Senex tenements, the relevant Aboriginal heritage bodies concerned shall be identified and a DSD-AAR Register search completed as required. Under Cultural Heritage Agreements and determinations and in consultation with the relevant Aboriginal parties, the following strategies are in place to avoid damage, disturbance or interference to Aboriginal sites, objects or remains:

Pursuant to s20 of the Aboriginal Heritage Act (AHA) 1988 any sites, objects or remains identified during surveys and their original locations are to be recorded, mapped and site cards and reports are to be submitted to DSD-AAR as applicable.

Traditional Owners are to return any objects removed or relocated as during activities to "Country". It should also be noted that only the Minister for Aboriginal Affairs can authorise damage, disturbance or interference to Aboriginal sites, objects or remains and that includes removing or relocating objects.

Further to this site specific Work Area Clearances are carried out with the relevant Native Title group in advance of all activities to ensure that cultural heritage values and significant places are not impacted.



4.8.2 Non-Aboriginal Cultural Heritage

Non-indigenous heritage in the region dates back to early exploration of the region in the mid to late 1800’s and the expansion of pastoralism. Many of the historical sites in the region are associated with the failed Burke and Wills expedition of 1860-61 (including the Dig Tree and grave sites) and the subsequent settlement of inland South Australia and Queensland and the establishment of transport routes and pastoralism (Planning SA 2009, AHPI 2009).

Locations around Innamincka are incorporated within the Innamincka/Cooper Creek State Heritage Area and contain significant sites listed on the Register of National Estate. A number of sites in the region are listed on the State Heritage Register, including the Australian Inland Mission Nursing Home at Innamincka and the Innamincka / Cooper Creek State Heritage Area (a section 1 km either side of the Cooper Creek channel from the Queensland border to 14 km west of Innamincka).

4.8.3 Native Title

There are currently three Native Title Claims in the South Australian Cooper Basin. Details of each claim are presented in Table 11.

Table 11: Native Title claims in the South Australian Cooper Basin

Title Location Status

Yandruwandha/ Yawarrawarrka Native Title Claim

North east corner of South Australia (SA) extending south to Lake Blanche.

Registered

SC98/1

Dieri Native Title Claim From Marree in the south to Cameron Corner in the east, to Hadden Corner in the north east, following the Qld border to Lake Teetatobie, south west of Gypsum Cliff, west to Lake Eyre, south to Marree.

Registered

SC97/4

Wangkangurru / Yarluyandi Native Title Claim

Northern SA and Queensland. Registered

SC97/3

Senex has agreements in place for its licence areas with the relevant Native Title claimant groups covering exploration and production. Before Senex conducts activities, work area clearances are undertaken with representatives engaged from the relevant group.

4.8.4 Land use

The major land uses in the Cooper Basin are pastoralism, oil and gas exploration production, conservation and tourism.

Pastoralism

Pastoralism, mainly in the form of cattle grazing, has a long history in the region, beginning in the late 1800s and continuing today. The floodplains surrounding the Cooper Creek in particular provide pasture and reliable water supplies in the form of permanent waterholes. While stocking rates are relatively low the region continues to support a substantial cattle production operation which is an important contributor to the local economy.

Pastoral leases in the region include:

Alton Downs Bollards Lagoon Clifton Hills Cordillo Downs Gidgealpa Innamincka Lindon Merty Merty Mulka Mulka Mungeranie



Pandie Pandie

There are a number of properties in the region that have achieved certification for organic beef production. Landholders in Senex’s operational regions are also certified under Quality Assurance systems such as the Livestock Production Assurance Program or Cattlecare, which places emphasis on minimising the risk of chemical contamination, bruising and hide damage and ensuring effective herd management and improvement.

Oil and Gas

Oil and gas exploration in the Cooper Basin commenced in 1954 and the Cooper Basin has become a major supplier of oil and gas in Australia since the discovery of gas reserves at Gidgealpa, near Moomba, in 1963. The actual area of land utilised for gas production is small, but the supporting infrastructure extends throughout much of the central and north eastern portion of the Cooper Basin in South Australia. Producing oil and gas fields are spread through pastoral lands and regional reserves and the Ramsar wetland declared area.

Senex is a major oil producer in the South Australian Cooper Basin, with a number of oil production facilities in the Basin and a strong acreage position on the Cooper Basin's western flank. Senex is also working towards developing a large-scale, cost-competitive unconventional gas resource in the Cooper Basin.

Beach Energy has two main operational bases in the Basin, producing oil and some gas, and is the second largest petroleum operator in the region. Beach is a joint venture partner in a number of Senex Energy’s fields.

Conservation

The region contains some of South Australia’s largest reserves dedicated under the National Parks and Wildlife Act 1972. The main parks and reserves of the broader region include the Innamincka Regional Reserve, Strzelecki Regional Reserve, Simpson Desert Regional Reserve and the Coongie Lakes National Park.

Regional Reserves are areas proclaimed for the purpose of conserving wildlife, natural or historical features while allowing responsible use of the area’s natural resources (including oil and gas production). The main regional reserves in the Cooper Basin are the Innamincka Regional Reserve and Strzelecki Regional Reserve which account for just over 2 million hectares of land while the Simpson Desert Regional Reserve, located on the western margin of the region is the largest protected area in South Australia and plays an important role for landscape-scale conservation of central Australian arid environments.

Coongie Lakes National Park was originally part of the Innamincka Regional Reserve and forms the core of the extensive Coongie Lakes system of wetlands and near-permanent freshwater lakes. The national park was proclaimed to conserve significant wetlands, provide tourism experiences and ensure that the core component of the Coongie Lakes system is protected from grazing, petroleum and mining activities.

To protect wetlands adjacent to the park and ensure that activities in the adjacent Innamincka Regional Reserve do not impact on the national park, three special management zones were established when the regional reserve was proclaimed. The No Mining Zone, the Walk-In Zone and the Controlled Access Zone provide protection to key riparian and wetland zones, ranging from exclusion of exploration and mining activities, to permitting walk-in activities and access subject to conditions over and above normal environmental and management requirements for the Cooper Basin.

The national park is situated within the Coongie Lakes Ramsar wetland, a larger area which was listed under the Ramsar Convention as a Wetland of International Importance in 1987, in recognition of its important role in providing refugia for the conservation of migratory and nomadic birds. It is estimated that the Coongie Lakes Wetlands Ramsar area covers 30% of the known oil and gas resources within the South Australian portion of the Cooper Basin (DEHAA 1999).



Senex’s PEL 182 licence area is adjacent to the Coongie Lakes National Park and No Mining Zone, and encompasses the Walk-In Zone and the Controlled Access Zone.

Tourism

The Innamincka, Coongie Lakes and Cooper Creek regions in north-eastern South Australia have increased in popularity over the past 30 years as a destination for tourists seeking a bush exploration experience. It is estimated from available data that over 17,500 visitors travelled through Innamincka between July 2007 to January 2008 and that annual visitation exceeds 34,500 visitors (DEH 2008). Dillons Highway (Strzelecki Track) is a major tourist access route to the region and after connecting with the Adventure Way east of Innamincka, forms part of the outback tourist highway between South Australia and Queensland. The Birdsville Track which connects the towns of Marree in South Australia and Birdsville in Queensland is also a major tourist route in the north-west of the region.

4.9 Socio-economic

The region is located in the unincorporated (i.e. out of councils) area of South Australia. Jurisdiction for the area falls under the responsibility of the Outback Communities Authority which provides limited local government-type support.

As discussed above, the major regional industries are pastoralism, oil and gas production and tourism.

The only township in the region is Innamincka, which has had a resident population in the order of 12 to 18 people (Marree SCB 2004). The Innamincka Progress Association is responsible for managing many of the town’s public facilities, including the Town Common camping area, the airstrip and public amenities.

Moomba, Ballera and the satellite production facilities have accommodation and recreation facilities that house the petroleum industry workforce, which operates on a ‘fly-in, fly-out’ basis.

Infrastructure in the region is minimal. Unsealed roads service the district, with the Adelaide-Moomba Road and Dillons Highway (which are generally referred to as the Strzelecki Track) being the major route through the region. The Old Strzelecki Track between Merty Merty Station and Innamincka is not maintained as a major road and carries relatively low traffic volumes. The oil and gas fields in the region are serviced by a network of unsealed roads and tracks, which are generally not available for public access.

Other public roads in the region include the Adventure Way, east of Innamincka, the Cordillo road and Coongie Lakes track north of Innamincka, Fifteen Mile Track, west of Innamincka and the Walkers Crossing Public Access Route, north-west of Moomba. The Birdsville Track lies on the western edge of the region.



5 Environmental Risk Assessment

This section provides an assessment of the environmental risks associated with Senex’s production operations in the Cooper Basin. Section 5.1 provides an overview of the risk assessment methodology. Sections 5.2 to 5.10 contain discussions of hazards and tabular summaries of risk assessments and management strategies for Senex’s operations and activities in the Cooper Basin. Each risk assessment table outlines:

environmental hazards associated with the operation or activity the potential consequences of the hazard an outline of key management measures likelihood of occurrence of these consequences, given the management measures in place potential severity of the consequences, given the management measures in place, and the resultant level of risk.

5.1 Overview of Risk Assessment Process

Environmental risk is a measure of the likelihood and consequences of environmental harm occurring from an activity. Environmental risk assessment is used to separate the minor acceptable risks from the major risks and to provide a basis for the further evaluation and management of the major risks.

The risk assessment process involves:

identifying the potential hazards or threats posed by the project categorising the potential consequences and their likelihood of occurring using a risk matrix to characterise the level of risk

5.

The level of risk for Senex’s production operations in the Cooper Basin has been assessed based on the assumption that management measures that are discussed in this EIR will be in place. The risk assessment was carried out by RPS and Senex, based on knowledge of the existing environment, and experience with production operations in the Cooper Basin undertaken by both Senex and other companies (e.g. Beach Energy and Santos).

The risk assessment process was based on the procedures outlined in Australian and New Zealand Standard AS/NZS ISO 31000:2009 (Risk Management) and HB 203:2006 (Environmental Risk Management – Principles and Process).

The risk assessment uses Senex’s risk matrix and definitions for consequences and likelihood, as defined in Senex Risk Management Procedure SENEX-CORP-HS-PRC-009. These tables are outlined below. These tables use:

five categories of consequence (Negligible to Critical) to describe the severity, scale and duration of potential impacts

five categories of likelihood of potential environmental consequences occurring (Remote to Almost Certain). The likelihood refers to the probability of the particular consequences eventuating, rather than the probability of the hazard or event itself occurring.

a risk matrix to characterise the risk associated with each hazard. Five levels of risk are used, from Negligible to Extreme.

Definition of Consequences

To describe the severity, scale and duration of potential impacts, the five categories of consequence listed in the following table are used.

5:The risk assessment process is iterative for many hazards. For example, the risk assessment may initially indicate that risks

are unacceptably high, based on minimum or familiar management practices. In such cases, management practices are reviewed to identify additional management options to lower risk and/or improve environmental outcomes (e.g. elimination, substitution, reduction, engineering controls and management controls). The risk is then re-assessed based on these additional management options. This EIR details the final or residual risk after management options have been applied.



Table 12: Consequence definition

Health and Safety Natural Environment

Reputation Community/Media

Financial AUD$

Catastrophic 5 Fatality Critical ecological impact and/or regulatory intervention

Critical impact on business reputation, international media exposure

Financial loss in Excess of $25 million

Major 4 Permanent disability Significant ecological impact and/or regulatory intervention

Significant impact on business reputation, national media exposure

Financial loss $10 million to $25 million

Moderate 3 Lost time injury

Significant local environmental impact and/or regulatory intervention

Moderate impact on business reputation, local media exposure

Financial loss from $1.0 million to $10 million

Minor 2 Medical treatment

Minor local environmental impact and/or regulatory notification is required

Some impact on business reputation, local community exposure

Financial loss from $100,000 to $1.0 million

Insignificant 1 First Aid Injury Minimal impact to any local environment or issue

Minimal impact on business reputation

Loss up to $100,000

Definition of Likelihood

The likelihood of potential environmental consequences occurring is defined using the five categories shown in the following table. The likelihood refers to the probability of the particular consequences eventuating, rather than the probability of the hazard or event itself occurring.

Table 13: Likelihood definition

A HIGHLY LIKELY A common event that is likely to occur in the industry6 many times a year

B LIKELY An event likely to occur more than once a year in the industry

C POSSIBLE An event that may occur in the industry over 10 years

D UNLIKELY An event not likely to occur in the industry over 10 years

E REMOTE An event that has not previously been experienced in the industry but may occur in

exceptional circumstances

Characterisation of Risk

The risk associated with each hazard is characterised as negligible, low, intermediate, high or extreme

using the matrix below.

6 “Industry” includes activities related to onshore oil and gas in Australia



Table 14: Environmental risk matrix



Risk Level & Priorities for Action

Based on the risk ranking determined as per the risk matrix, Senex Energy’s Risk Management

Procedure requires that priorities for action should be determined in accordance with Table 15.

Table 15: Risk Treatment Actions

Risk Rating Risk Treatment Actions

Extreme

Immediate action required

Task must not proceed. It should be redefined or further control measures put in place to reduce risk (to ALARP levels). The controls should be re-assessed for adequacy prior to task commencement.

High

Senior Management attention required.

Modify the threat, the frequency or the consequences so that the risk rank is reduced to intermediate or lower.

Task should only proceed with appropriate management authorisation and after consultation with specialist personnel and assessment team.

Intermediate

Management responsibility must be specified.

Generally acceptable level of risk where further risk reduction is shown not to be practicable.

Task should only proceed with appropriate management authorisation and after consultation with assessment team.

Low

Manage by routine work instructions / procedures.

Generally considered to be a low risk. Further risk reduction measures should always be considered but may not be practicable.

Negligible Review at next review interval

5.2 Production Facilities

5.2.1 Facility Construction

Environmental hazards associated with construction of facilities and associated areas such as camps and laydowns include movement of heavy vehicles, earthworks, vegetation clearance, fire, spills associated with chemical and fuel storage and waste disposal.

The type and severity of potential consequences of earthworks is dependent, to a certain extent, on the land system in which the activities are being carried out. Disturbance of soils in some land systems, such as gibber plains and tablelands, can lead to substantial erosion by water while other systems, such as dunefields, are generally more resilient and less likely to suffer any long-term impacts from soil disturbance.

Production facilities are usually located on or adjacent to previously disturbed areas (e.g. drill pads, access tracks) to minimise the need for additional land disturbance and vegetation clearance. Production facilities are also usually located to avoid sensitive land systems or areas of high ecological value (e.g. salt lakes, wetlands and areas subject to periodic inundation or other areas of significant habitat). The potential consequences of specific earthwork activities on different land systems in the Cooper Basin are summarised in Table 19.

Vegetation clearing, can result in loss of vegetation and fauna habitat, increased erosion, siltation of natural drainage lines and watercourses, destabilisation of creek crossings, weed invasion and damage to cultural heritage sites. Vegetation clearance may also impede the movement of fauna around the construction site. Care is taken when planning the location of a facility site to ensure that minimal vegetation is cleared. A potential source of leaks and / or spills during construction is from chemical and fuel storage areas and refuelling depots associated with construction works. The primary consequence of any leak or spill is localised contamination of soil.



Occurrence of flooding or fire during construction works has a number of potential consequences. For flooding these include significant soil erosion in areas that have been subject to earthworks and possibly loss of vegetation. In the case of a fire, loss of vegetation and fauna habitat and production of particulate air emissions are possible consequences. Facility construction generates some waste. Materials such as metal off-cuts or wooden pallets can generally be reused or recycled.

5.2.2 Facility Operation

There are a number of environmental hazards associated with the operation of oil or gas production facilities. They include production of atmospheric emissions (via fugitive, flare, combustion and venting sources), loss of containment of oil and storage of chemicals and fuels. These are outlined in Table 16. Emissions of environmental significance (i.e. known atmospheric pollutants and/or greenhouse gases) are:

combustion by-products (e.g. oxides of nitrogen, carbon monoxide and sulphur dioxide) methane and organic carbon from fugitive sources vented gas flared hydrocarbons vented CO2, H2S, and CO.

Operation of compressors or generators can result in an increase in background noise levels, which may result in disturbance to wildlife, stock or third parties (e.g. if facilities are inappropriately located near pastoral residences or tourist campsites). The presence of personnel and site activities also has the potential to disturb stock or wildlife, particularly if sites are inappropriately located near yards or significant habitats.

There is the potential for accidental spills or leaks of small amounts of process chemicals (e.g. PFW emulsion breakers), cleaning chemicals or fuels during storage or handling and use. Accidental spills/release of oils may also occur as a result of flowline failure or leaks from equipment such as the inlet header, pipeline connection or plant valves. There is also a potential for accidental overflow of oil storage tanks at production facilities and for spills to occur during tanker loading activities.

Leaks, spills and overflows can potentially lead to localised contamination of soil within the production site and may be a potential ignition source for fire. The risks associated with leak or spill hazards are minimised through appropriate storage and containment and implementation of storage and handling procedures. All chemicals and fuels (including oil storage tanks) are stored on impervious bunded surfaces in accordance with AS 1940:2004 and EPA ‘Liquid Storage - Bunding and Spill Management Guidelines 080/12’ (2012). This includes, but is not limited to, fuels and chemicals being stored with appropriate secondary containment such as double skinned tanks (fuel storage), appropriate bunding capacity for chemicals and flammable liquids in accordance with EPA requirements, and the undercover storage of chemicals where practicable.

Flooding of production facilities in floodplain areas can lead to contamination of soil and water, particularly if flood levels are high enough to overflow bunded areas or damage infrastructure (e.g. ponds). Flooding as a result of seasonal flows of the Strzelecki Creek or the Cooper Creek is not expected to affect most Senex facilities which are located to avoid areas subject to inundation. If flooding of a facility by an approaching Cooper Creek flood event is predicted, a range of management strategies can be implemented (e.g. ceasing of production operations at the facility / field, construction of bunds where appropriate to increase protection, skimming of interceptor pits and removal of hydrocarbons off site). Previous major floods of the Cooper Creek have inundated oil fields in the Cooper Basin and with management strategies in place no significant environmental consequences have resulted.

Some Senex facilities have, or will have, accommodation and offices to house personnel working at the facility. The primary hazards associated with these facilities are the storage and handling of domestic waste and sewage. These hazards are dealt with in Section 5.9. Due to the nature of processing operations there is also an inherent risk of explosion or fire. However this risk is reduced to As Low As Reasonably Practical (ALARP) by implementing various management measures to minimise the risk.



Table 16: Production facility risk assessment

Activity/Event Potential Consequences Management Strategy Consequence Likelihood Residual Risk

Earthworks associated with facility construction (e.g. clearing, grading)

Injury or death of fauna/stock in construction area

Long term disturbance to natural drainage patterns

Significant damage to third party infrastructure

Soil erosion and siltation of watercourses

Inversion of soil profile

Dust generation

Soil compaction of the easement

Impeded fauna movement through construction area

Damage to native vegetation

Temporary loss of visual amenity

Disruption to land use (e.g. grazing and recreation)

Encroachment (surface) into PEL182 Walk-In Zone

Minimise environmental impact by appropriate site selection to avoid sensitive land systems, vegetation and cultural heritage sites.

Use existing disturbed areas where possible

Liaise with landowners regarding notification and management of works and site issues including livestock management

Observe procedures and guidelines for the identification, management and protection of cultural heritage sites, including obtaining heritage clearances by Native Title groups

Minimise vegetation disturbance, and plan construction to avoid vegetated areas

Stabilise and control areas where there is potential for or signs of soil erosion or siltation occurring.

Avoid significant or priority7 vegetation and ensure proposed site has

been scouted for significant vegetation and wildlife habitats by appropriately trained and experienced personnel

Where possible trim vegetation rather than clearing

Undertake vehicle and equipment washdown in accordance with the management strategy and using a risk–based approach before entering Cooper Basin or after operating in areas of known weed infestations.

Discharge water (e.g. vehicle and equipment wash-down water) appropriately collected and disposed of in accordance with ANZECC and EPA criteria.

Records of vehicle inspections and wash down are kept on file.

Minimise consequences to fauna by leaving excavated areas open for as little time as possible

Utilise fauna ladders (sticks etc.) to facilitate the movement of fauna out of excavations

Daily inspection of excavations for trapped fauna

Reinstate temporary construction areas (e.g. laydown) as soon as possible

Site selection, environmental management and restoration of borrow pits undertaken in accordance with the SEO (Senex, 2016) and DSD GAS Criteria for the construction, management and rehabilitation of

Minor Possible Low (C2)

Disturbance to cultural heritage sites

Introduction and/or spread of weeds

Moderate Possible Intermediate (C3)

7 Wiltshire, D. and Schmidt, M. (2003). Field guide to the common plants of the Cooper Basin, South Australia and Queensland. Santos Ltd, Adelaide.




borrow pits (DSD, 2014). Existing borrow pits are used in preference to new ones where appropriate.

Re-use of borrow pits as PFW evaporation or water storage ponds where appropriate and with DSD agreement

Remove waste to minimise visual impact

Restore natural contours to minimise consequences to natural drainage patterns

No blockage of any creek1 channels within the PEL182 Controlled

Access Zone (CAZ).

No earthmoving activities to occur within the PEL182 CAZ when floodwaters pose an inundation risk of the area where earthworks are occurring or proposed to occur.

Explosion or fire at the production facility

Danger to health and safety of employees, contractors and possibly the public

Contamination of soil and/or watercourse

Atmospheric pollution

Burning of vegetation and habitat

Injury to or loss of native fauna

Disruption to land use (e.g. grazing)

Access to contaminants by stock and wildlife

All production facilities are designed and constructed in accordance with relevant standards (e.g. AS3000, AS1940, AS 2885).

Safety, testing, maintenance and inspection procedures are implemented

Establishment of appropriate emergency/spill response procedures for explosion or fire

Erection signage and, where required, fencing to delineate restricted/hazardous areas

Personnel are trained to supervise and instruct individuals entering area to conduct work

Appropriate firefighting equipment at all production facilities

Safe work permits must be obtained to ensure only individuals with proper clearance can conduct works

Smoking only in designated areas located away from equipment or activity

Petrol vehicles to be excluded from restricted areas

Appropriate firebreaks are maintained

Immediate clean up and remediation of spills to minimise contamination to soil/water

Major Unlikely Intermediate (C4)

Flooding of surrounding floodplains / watercourses

Contamination of soil, surface water and/or groundwater

Damage to infrastructure (e.g. evaporation ponds)


Damage to or loss of surrounding vegetation and fauna by contaminated water

Production facilities located to avoid areas subject to inundation as far as possible.

Implementation of Senex Flood Monitoring Procedures and Senex Flood Management Protocols where flooding of operational areas is likely or imminent (e.g. well heads shut-in, fuel and chemicals removed, contents of flowlines/pipelines secured)

Moderate Unlikely Low (D3)




Production operations will cease in event of imminent flood inundation of the facility. In floodplain land systems, the following steps will be undertaken well in advance if there is a risk of facility flooding:

Satellite imagery and upstream flood levels used to predict when floodwaters will reach the facility (generally take 2-3 months to reach lower Cooper)

Construction of bunds around wells. where appropriate, to increase protection

Additional inspections will be conducted Flowlines in floodplain areas will be designed to maintain

integrity during inundation. Interceptor pit (if present) skimmed to remove oil Fuel tanks drained, engines and all hydrocarbons (e.g. fuel and

lubricants) removed off-site Office/accommodation units tied down

Previous major floods of the Cooper have inundated oil fields in the Cooper Basin and with management strategies in place no significant environmental consequences resulted.

Appropriate spill containment equipment available at sites located near watercourses e.g. floating containment booms, absorbent materials to enable immediate confinement and clean-up

Production facilities will be designed to avoid spread of hydrocarbons during inundation following localised rainfall (e.g. appropriately sized/elevated bunds)

Spills or leaks associated with chemical and fuel storage and handling



Implementation of appropriate chemical and fuel storage and handling procedures (e.g. bunding, signage) in accordance with relevant standards, including AS1940:2004, EPA Bunding and Spill Management Guidelines and the Australian Dangerous Goods Code (ADG).

Regularly educate staff of product, review and monitor chemical and fuel storage, including signage/labelling, proper packing and tie downs

Implementation of appropriate emergency/spill response procedures in accordance with the Senex Emergency Management Plan and Senex Spill Response Plan

Spill containment equipment available at sites located near watercourses e.g. floating containment booms, absorbent materials to enable immediate confinement and clean-up.

Periodic review and exercise of response equipment and procedures to ensure preparedness

Immediate clean up and remediation of spills to minimise





contamination to soil/water

Fencing of contaminated areas if threat is posed to stock or wildlife

Maintain a register of spills and/or leaks and implement corrective actions based on analysis of spill events

Tanker Load-out Contamination of soil and/or watercourse


Tanker load-out in lined area, with appropriate EPA compliant bunding to contain spills

Construction and operation of filling systems, storage tanks and the tankers in accordance with AS 1940:2004

Spill kit/s located at the load-out.

Hoses with dry-break couplings

Personnel attendance at all times during tanker filling

Also refer to strategies listed for Spills or Leaks above.


Fugitive emissions of methane and organic carbon

Venting of CO2, H2S, and CO

Venting of gas

Release of greenhouse gases contributing to climatic warming

Localised reduction in air quality

Continual review and improvement of operations

Reporting of emissions in accordance with statutory requirements (e.g. NPI and NGER requirements)

Insignificant Likely Low (B1)

Flaring or combustion of hydrocarbons

Release of greenhouse gases contributing to climatic warming


Continual review and improvement of operations

Selection of equipment to minimise emissions

Maintenance of plant and equipment in accordance with manufacturer’s specifications

Reporting of emissions in accordance with statutory requirements (e.g. NPI and NGER requirements)


Loss of containment of oil outside area designed to contain spills (pipe rupture or leaks from plant equipment)

Danger to health and safety of personnel, contractors and possibly the public

Contamination of soil, and/or watercourse


Loss of vegetation and fauna habitat

All pipelines are designed, constructed and operated in accordance with relevant standards including inspections and maintenance

Creek 8crossings of pipelines in the PEL182 Controlled Access Zone

(CAZ) shall include two physical mechanisms2 and two systematic

mechanisms9 of oil spill protection.

Construction and operation of filling systems, storage tanks and the tankers in accordance with AS 1940:2004

Use of steel piping and fittings where possible


8Creeks are defined as those minor and major watercourses mapped to occur within the CAZ by the DEWNR topographical watercourse mapping dataset (DEWNR, 2016).

9 2As defined by measures outlined in AS2885 Pipelines-Gas and liquid petroleum Part 1: Design and construction Section 5.5.4.




Appropriate areas (e.g. storage tanks) bunded and lined to contain spills in accordance with EPA Bunding and Spill Management Guidelines.

Oil storage tanks placed within an appropriately designed bund



Immediate clean up and remediation to minimise contamination to soil/water




Presence of personnel, site activities and noise emissions

Disturbance to landowners and other third parties

Disturbance to stock and wildlife

Visual impact

Appropriate site selection to avoid site establishment where significant disturbance to wildlife, pastoral residences or tourist sites are likely


Maintenance of plant and equipment in accordance with manufacturer’s specifications

Reasonable practical measures implemented to comply with the requirements of the EPA Environment Protection (Noise) Policy

Maintain a high standard of ‘housekeeping’ to minimise visual impact


Access and activity of personnel outside designated facility area / work areas

Damage to vegetation and habitats

Damage to cultural heritage sites

Training and induction of all personnel and visitors includes information on restricted areas and activities

Vehicle access restricted to designated roads and areas

Erection of fencing and signage to delineate restricted areas



2As defined by measures outlined in AS2885 Pipelines-Gas and liquid petroleum Part 1: Design and construction Section 5.5.4 - Table 5.5.4(A) and Table 5.5.4(B).



5.3 Produced Formation Water

The most significant hazard associated with the operation of petroleum production facilities is the storage and treatment of large volumes of produced formation water (PFW). PFW can be highly saline and contain chemicals (both natural and added), residual hydrocarbons and some naturally occurring heavy metals.

Potential contamination of soil and groundwater may result from leaks in separation tanks, interceptor ponds and bunded or free form evaporation ponds. Subsurface movement can also lead to upwelling of PFW outside of evaporation ponds. However the likelihood of the loss of containment of the storage of PFW is considered rare with appropriate control measures and management strategies in place.

The potential environmental consequences associated with PFW disposal include:

contamination of soil and near surface aquifers by any carried over hydrocarbon or process chemicals (e.g. emulsion breakers or biocides used to prevent corrosion resulting from sulphur reducing bacteria) or naturally occurring metals

contamination of soil and associated vegetation with salts and metals naturally occurring, but concentrated in the PFW

ingestion of contaminants by native fauna or stock.

There is also potential for birds and other wildlife to come into contact with high temperature water, residual hydrocarbons and other contaminants (such as heavy metals) in interceptor pits. Oiled birds may suffer from restricted movement and distress and often do not survive the effects of ingesting oil and other hydrocarbons.

A research project conducted by Santos indicated that the principal contaminants of concern in PFW ponds are mercury, polycyclic aromatic hydrocarbons (PAH), total petroleum hydrocarbons (TPH) and total phenolics (Santos 2003a; 2010).



Table 17: PFW storage and disposal risk assessment


Storage and disposal of PFW at production facilities

Contamination of soil and/or groundwater


Salinisation of adjacent areas

Death of adjacent vegetation

Injury to or death of wildlife

Site ponds appropriately10

to minimise potential consequences (e.g. isolated from floodplains and areas of frequent inundation).

Construct ponds using appropriate materials and suitable design criteria including adequate freeboard, depths, lining, bunding etc.

Ensure that interceptor pits are appropriately lined with an impermeable liner (e.g. HDPE)

Surface of interceptor pits to be regularly skimmed

Ensure that tanks are well maintained and regularly emptied

Ensure adequate freeboard is maintained on ponds

Monitor ponds for surrounding upwelling of PFW

Undertake appropriate water quality monitoring where shallow groundwater exists in the vicinity of PFW ponds

Monitor and audit evaporation pond sludge and water annually to ensure that relevant oil in water criteria are met

Periodic review of PFW and implementation of audit recommendations

Minimise use of process chemicals (e.g. biocides, emulsion breakers) and use biodegradable or UV degradable chemicals where available

PFW ponds fenced to prevent wildlife and stock access.

Repair any damaged fences or gates

Maintain a register of spills and/or leaks and remediate

Breaker siphon to be installed between interceptor pond and evaporation ponds

Record fauna entrapment or deaths if they occur and implement appropriate preventative measures if required.


Secondary use of PFW



Salinisation of adjacent areas

Death of adjacent vegetation

Quality of water analysed prior to secondary use to ensure that it meets relevant criteria (e.g. ANZECC criteria for the intended site/use).

Visual monitoring undertaken at secondary use sites as appropriate (e.g. salinity, vegetation health, contamination).

Relevant approvals obtained where required (e.g. DSD, landholder)

Secondary use for road watering or dust suppression avoided in areas where contaminants may enter surface waters.


10 Appropriately manage means to take into consideration and assess relevant environmental factors (including location of surface water, potential flooding, location of vegetation, etc.) and take

measures to reduce the potential impact on these factors through the use of best practice.




Flooding of surrounding floodplain / watercourses

Refer to Production Facility Impact Assessment (Table 16)



5.4 Waterflood

The major hazards associated with water injection schemes include packer failure or loss of well integrity, injection of non-compatible waters into the aquifer and the potential for spills of saline waters and/or any chemical product that may be used for treating the water prior to injection.

Packer failures are unlikely and injection wells are routinely tested for leaks of the packer or tubulars. If the packer fails there may be little or no hazard to third parties or to the reservoir (e.g. if there are no perforations above the packer). Other downhole issues such as well casing and cementing failure are unlikely as injection pressures will be well below the pressure rating of the casing.

Quality and compatibility testing would be conducted on the injection water to ensure that there is no contamination of the aquifer / reservoir being injected into. The injection water would have a scale inhibitor and a biocide added to it to condition the water. The amount added to is minute in comparison to the volume of water in the reservoir that it will be in contact with. Water quality testing would be conducted frequently to ensure consistency of injection water quality.

Waterflood activities are only undertaken in reservoirs with good containment, which ensures that the injection water will stay within the target formation.

Radiotracers (if used) are injected into the water injection well under controlled procedures by licensed contractors using a sealed system. The tracers that are typically used (e.g. tritium and iodine) are specifically used due to their low cost and safety. These types of tracers are indicated to have a negligible external radiological effect and are generally not considered to be harmful to people or animals.

The injection water would be likely to be transferred through new installed polyethylene, steel or composite lines that are rated and tested to meet project requirements. Water injection skids would have high-low shut downs and be monitored by telemetry. A spill of produced formation water intended for injection would be expected to pose a relatively low hazard.

Waterflood injection programs would be subject to detailed assessment and would require approval from DSD (and possibly EPA and / or DEWNR depending on injection parameters) before commencement.



Table 18: Waterflood risk assessment


Packer failure or loss of well integrity during injection

Contamination of aquifers Well contents (i.e. injected water) isolated from shallower aquifers by tubing and casing in well

Regular pressure measurements undertaken to ensure well integrity is maintained (e.g. to ensure no communication between the tubing and casing)

Cement Bond Logs will be run to test for poor cement bonds

Integrity of the well bore and packer are routinely tested.

Major Unlikely Intermediate (D4)

Injection of contaminated water into the target or other aquifer zones

Aquifer or reservoir contamination Frequent quality testing of injection waters

Compatibility studies conducted prior to injection.

Filtering of water to promote efficient injection into formation


Spill or leak associated with transportation of waters from the production facility to the water injection well

Localised acidification and/or salinisation of soil.

Equipment designed and operated in accordance with relevant standards and guidelines

Water injection skid equipped with shut downs and injection monitoring.

New steel, polypropylene or composite piping tested and maintained to design conditions.

Pipeline monitored for leaks (pressure gauges and visual inspection)

Produced water may be treated in a hydro-cyclone to reduce oil in water content where required

Maintain register of spills/leaks

Immediate clean-up and remediation if any spills or leaks occur


Spill of radioactive waterflood tracer

Localised contamination of soil.

Danger to health and safety of employees and contractors

Radiological Safety procedures conducted by specialists hired to conduct work.

State controls on radiotracer substances followed.

Conduct of regular inspections, and regular maintenance, follow specific operating procedures for working with tracers. Ensure individuals in areas of responsibility are trained to handle events.

In the event of a spill or leak follow appropriate emergency response procedures

Minor Unlikely Negligible (D2)



5.5 Pipelines / Flowlines

5.5.1 Pipeline Construction

Environmental hazards associated with pipeline construction include movement of heavy vehicles, earthworks, vegetation clearance, fire, spills associated with chemical and fuel storage and waste disposal. Flooding (of the Cooper Creek or Strzelecki Creek floodplain and associated watercourses e.g. Christmas Creek) may also need to be considered to be potential environmental hazard if pipeline construction is required in the vicinity of these areas.

Movement of heavy vehicles (e.g. trucks and side boom tractors) along the construction easement and access tracks is an environmental hazard as there is a possibility that vehicles may inadvertently damage vegetation, generate dust and / or compact soil if not appropriately managed. Earthworks can result in similar consequences as well as potentially disturbing sites of cultural significance and exposing soils to wind and water erosion.

The type and severity of potential consequences of earthworks is dependent, to a certain extent, on the land system in which the activities are being carried out. Disturbance of soils in some land systems, such as gibber plains and tablelands, can lead to substantial erosion by water while other systems, such as dunefields, are generally more resilient and less likely to suffer any long-term impacts from soil disturbance. Studies of seismic lines in dunefields in the Cooper Basin have indicated that natural rates of erosion on dunes were not accelerated as a result of disturbance to the soil surface (SEA, 1999).

Wetlands are avoided under most circumstances when planning pipeline routes as they are often of high ecological value and sensitivity. Salt lakes are also avoided as rehabilitation is difficult to undertake and they are therefore likely to be severely scarred by pipeline construction activities. The potential consequences of specific earthwork activities on different land systems in the Cooper Basin are summarised in Table 19.

Other activities along the construction easement, such as vegetation clearing, can result in loss of vegetation and fauna habitat, siltation of natural drainage lines and watercourses, destabilisation of creek crossings, weed invasion and damage to cultural heritage sites. Vegetation clearance may also impede the movement of fauna within the construction zone. Particular care is taken to ensure that minimal vegetation is cleared in Coolibah woodland during easement preparation. The easement is generally minimised (to approximately 10 m for smaller diameter flowlines) in any heavily wooded areas.

The presence of an open trench during construction of buried pipelines has the potential to result in fauna entrapment and mortality. The length of time the trench is open is minimised as far as practicable, but for some pipeline installations (e.g. GRE pipe) there may be a need to keep the trench open for long periods (several weeks or more) to allow for identification and repair of any leaks that are detected during hydrostatic testing. Measures such as installation of trench plugs or escape ramps are implemented, and the trench is inspected daily (by appropriately trained project personnel or fauna monitors where appropriate) to detect and release any trapped fauna.

A potential source of leaks and/or spills during construction is from chemical and fuel storage areas and refuelling depots associated with construction works. The primary consequence of any leak or spill is localised contamination of soil. Discharge of hydrostatic test water to ground surface is another potential source of localised soil and groundwater contamination.

The use of biocides and chemicals in hydrostatic test water is required under some circumstances to prevent internal corrosion of the pipeline. Disposal of hydrostatic test water which contains biocide or other chemicals may be into existing lined evaporation ponds (i.e. produced formation water facilities) or to specifically constructed pits sited to prevent contamination of surface or near surface waters. Following consultation with the regulator, test water that is free of additives and demonstrated to comply with the ANZECC and EPA criteria for discharge may be disposed of to land adjacent to the construction zone.



Occurrence of flooding or fire during construction works has a number of potential consequences. For flooding these include significant soil erosion in areas that have been subject to earthworks and possibly loss of vegetation. In the case of a fire, loss of vegetation and fauna habitat and production of particulate air emissions are possible consequences.

Pipeline construction generates very little waste. Many materials such as pipe off cuts, rope spacers and timber skids can generally be reused or recycled. Excess soil/fill from pipeline trenching will be respread over pipeline and along the ROW. All remaining waste materials are removed from the work area and disposed of at an appropriately licensed landfill.



Table 19: Consequences associated with earthworks in various Cooper Basin landforms

Land form Activity/Event

Grading Trenching and Backfilling Excavation/Digging (e.g. borrow pits) Soil Stockpiling

Wetlands N/A N/A N/A N/A

Floodplains Soil erosion (wind and water)

Soil compaction

Disturbance of natural drainage systems (construction easement typically restricted to 8m at creek crossings)

Disturbance to cultural heritage sites (generally low density of sites in floodplains)

Disturbance of natural drainage systems (construction easement typically restricted to 8m at creek crossings)

Inversion of the soil profile


Impeded fauna movement

Soil erosion (wind and water)

Disturbance of natural drainage systems


Disturbance of natural drainage systems (e.g. saltation)


Gibber Plains N/A Soil erosion (particularly susceptible to water erosion e.g. severe gullying)

Disturbance of natural drainage systems (e.g. siltation)




Soil erosion (particularly susceptible to water erosion e.g. severe gullying)







Tablelands N/A Soil erosion (particularly susceptible to water erosion e.g. severe gullying)

Soil compaction





N/A Soil erosion (wind and water)



Dunefields Soil erosion (wind and water erosion)

Disturbance to cultural heritage sites (dunefields near waterholes are typically of high cultural significance)

Soil erosion (wind and water erosion)




Soil erosion (wind and water erosion)



Soil erosion (wind erosion)


Salt Lakes N/A N/A N/A N/A

N/A – not applicable as the activity is not carried out in this land system.



5.5.2 Pipeline Operation

The primary hazard associated with the pipeline operation is the loss of containment of oil or natural gas. Accidental spills and leaks may result from pipeline failure, which may be caused by:

heavy vehicle traffic (e.g. collision with an above ground pipeline) corrosion of steel pipelines (external or internal) natural events which stress the pipeline (e.g. flood / earthquake) overpressure pipeline material defects or construction faults.

Senex has implemented systems and processes to ensure pipeline structural integrity is maintained for the design life of the pipeline. This may include management techniques such as hydrotesting, cathodic protection, routine pigging, non-destructive testing (NDT) and periodic inspections.

Regular inspection of pipelines and monitoring of the performance of cathodic protection devices on buried steel pipelines is undertaken, to ensure that protection levels are adequate.

On composite pipelines (e.g. reinforced thermoplastic pipe) protection from corrosion is typically provided by an external thermoplastic jacket. The jacket provides protection from unusual external conditions (e.g. collapse resistance from hydrostatic pressure in deep water). Corrosion protection on composite pipelines is typically only required for pipe-to-pipe, but may also be required for buried end connectors when connecting to an external non-metallic piping system. In addition connectors shall be coated to reduce the likelihood of external corrosion. Composite pipelines may also have a HDPE inner layer which provides corrosion resistance that is suitable for the normal chemical and temperature ranges encountered in oil and gas applications. Regular inspection of the corrosion protection devices is untaken to ensure adequate protection.

Major pipelines in the Cooper Basin are also regularly pigged to remove water and sludge that accumulates at low points within pipelines. Sludge often supports sulphide reducing bacteria that are a significant cause of internal corrosion of pipelines in the Cooper Basin and testing is routinely carried out to detect potential for sulphide reducing bacteria.

Above ground pipelines are regularly inspected to ensure that they do not come into contact with the ground as a result of soil movement or failure of pipe supports. Where contact occurs ‘long line corrosion cells’ may form and result in rapid pitting of the pipe and possible pipeline rupture.

A gas or oil leak from a flowline may result in the release of gas to the atmosphere or contamination of soil or groundwater respectively. The potential exists for oil and condensate to be spilt at any point between an oil well and production facility. Many of the consequences associated with oil spills and leaks, such as vegetation loss, soil disturbance and drainage alteration can be minimised if spills or leaks do occur. However, this largely depends on the land system involved.

In dry environments, such as dunefields and gibber, the consequences associated with an oil spill are mainly localised, as oil is easier to contain and recover in dry conditions. However, the environmental consequences of oil spills in more sensitive wet environments, like the Cooper and Strzelecki Creeks and surrounding floodplains and wetlands, are potentially significant. Of primary concern are flood conditions that can potentially spread oil over large distances and throughout highly sensitive ecosystems. Additional pipeline protection measures are implemented in these areas in accordance with AS 2885 (e.g. increased wall thickness, increased depth of burial, monitoring and leak detection systems). Emergency response plans will be in place and will deal with the response to a spill or leak to surface water.

Fire and explosion are also possible hazards associated with pipeline operation. A fire or explosion along a pipeline can pose a danger to personnel, contractors and possibly the public and can potentially produce significant amounts of atmospheric emissions. The risk is reduced to As Low As Reasonably Practical (ALARP) by management measures. The potential for explosion or fire associated with oil pipelines is considered low due to the low volatility and flammability of oil and therefore the potential severity of the consequence is minor. The potential for explosion or fire associated with gas pipelines are considered low as all gas pipelines are designed, installed and



operated in compliance with AS 2885 (i.e. with appropriate design features and management measures including wall thickness, depth of burial, pipeline marker signs, cathodic protection, monitoring, testing, maintenance and inspection procedures).



Table 20: Pipeline construction risk assessment

Hazard Potential Consequences Management Strategy Consequence Likelihood Residual Risk

Earthworks (e.g. clearing of construction easement, grading, trenching and backfilling)

Injury or death of fauna/stock in construction zone





Dust generation


Temporary disruption to land use (e.g. grazing and recreation)

Impeded fauna movement through construction zone





Minimise environmental impact by appropriate route selection to minimise or avoid sensitive land systems, vegetation and cultural heritage sites

Use existing easements where possible


Stockpile topsoil separately from trench spoil (subsoil) for use in reinstatement

Observe procedures and guidelines for the identification, management and protection of cultural heritage sites, including obtaining heritage clearances by Native Title groups


Avoid significant or priority11

vegetation and ensure proposed routes have been scouted for significant vegetation and wildlife habitats by appropriately trained and experienced personnel




Minimise consequences to fauna by leaving trenched areas open for as little time as possible

Utilise trench plugs and fauna ladders (sticks etc.) to facilitate the movement of fauna out of and across trench

Daily inspection of open trenches and excavations for trapped fauna

Backfill trenches or excavations using excavated subsoil (i.e. leave topsoil stockpiles undisturbed for reinstatement).

Reinstate construction areas including construction easement as soon as possible









Rip areas of compacted soil (except on gibber plains and tableland environments)

Respread topsoil

Site selection, environmental management and restoration of borrow pits undertaken in accordance with the SEO (Senex, 2016) and DSD GAS Criteria for the construction, management and rehabilitation of borrow pits (DSD, 2014). Existing borrow pits are used in preference to new ones where appropriate.

Borrow pits re-used as evaporation or water storage ponds where appropriate


Stockpile cleared vegetation and respread following construction to facilitate revegetation


No blockage of any creek1 channels within the PEL182 Controlled

Access Zone (CAZ).


Movement of heavy machinery and vehicles along construction easement and access tracks

Dust generation

Soil compaction

Soil erosion


Injury or death of native fauna



Damage to third party infrastructure


Increased public access to remote areas

Use existing cleared areas for laydowns and turn-arounds




Drive only on access tracks and construction easement

Rip areas of compacted soil (not on gibber plains and tablelands)


Spills or leaks associated with chemical and fuel storage and handling



Implementation of appropriate chemical and fuel storage and handling procedures (e.g. bunding and signage, use of drip trays and spill kits for refuelling) in accordance with relevant standards, including AS1940, EPA Bunding and Spill Management Guidelines and the Australian Dangerous Goods Code (ADG Code)

Regularly educate personnel of product, review and monitor





chemical and fuel storage, including signage/labelling, proper packing and tie downs


Implementation of Senex Flood Monitoring Procedures and Senex Flood Management Protocols where flooding of construction area is likely or imminent (e.g. fuel and chemicals removed)






No trucking of oil within the CAZ during periods when water courses are flooded and/or access roads are inundated.

Ignition of fire along construction easement



Release of particulate emissions to the atmosphere


Smoking only permitted in a designated safe areas away from equipment or activity



Appropriate firefighting equipment on-site

Petrol vehicles to be excluded from construction sites

Emergency response procedures should contain a bushfire scenario




Disposal of hydrotest water


Loss of or damage to vegetation and fauna habitat as a result of soil or water contamination

Soil erosion / scouring

Use of biocides and toxic chemicals are kept to a minimum and if biocides are necessary UV-degradable biocides (e.g. TPHS) shall be used where practicable

Disposal of hydrostatic test water which contains biocide and other

Insignificant Possible Low (C1)




chemicals may be into existing lined and fenced interceptor ponds, or to specifically constructed pits sited to prevent the contamination of surface or near surface waters

Disposal of hydrotest water to ground with regulatory agreement, where water quality meets ANZECC / EPA discharge criteria and no potential impacts to soil, water or vegetation.

Use of aerators / spray bars, geotextile, etc. to prevent soil erosion at discharge point where uncontaminated hydrotest water is released to land




Table 21: Pipeline operation risk assessment


Explosion or fire along a pipeline






All pipelines are designed and constructed in accordance with AS2885 including installation of appropriate warning signage

Composite pipelines are buried with increased depth of cover however transitions will be located above ground

Aboveground pipelines are steel

Separation distances and exclusion zones are maintained

Pipeline proximity fire breaks are cleared and maintained




Safe smoking areas away from equipment or activity


Spill or leak associated with pipeline failure to land


Damage to vegetation and habitat



All pipelines are designed and constructed in accordance with relevant standards including installation of appropriate warning signage


Export lines and high pressure flowlines associated with jet pumps have pressure monitoring/shutdown in case of leak

Creek1 crossings of pipelines in the PEL182 Controlled Access Zone



Establishment of appropriate emergency/spill response procedures for spills or leaks to soil and water











Spill associated with pipeline failure in a watercourse

Contamination of groundwater, surface water, soil and other riparian systems


Damage to vegetation and habitat



All pipelines are designed, constructed and operated in accordance with relevant standards

Monitoring and leak detection systems implemented

Creek1 crossings of pipelines in the PEL182 Controlled Access Zone




High pressure flowlines associated with jet pumps not installed across watercourse beds


Implementation of Senex Flood Monitoring Procedures and Senex Flood Management Protocols where flooding of operational areas is likely or imminent (e.g. contents of pipelines secured)








2As defined by measures outlined in AS2885 Pipelines-Gas and liquid petroleum Part 1: Design and construction Section 5.5.4 - Table 5.5.4(A) and Table 5.5.4(B).



5.6 Road Construction and Maintenance

The major hazards associated with road construction are earthworks, vegetation clearance, chemical and fuel storage and waste disposal. Earthworks and vegetation clearance can potentially result in soil erosion, interruption of natural drainage patterns, disturbance to cultural heritage sites, introduction and spread of weeds and loss of vegetation. Waste disposal and chemical and fuel storage associated with road construction activities and mobile earthworks camps can lead to localised soil or water contamination. As indicated in Section 3.4.1, the type and severity of potential consequences of earthworks is dependent, to a certain extent, on the land system in which the activities are being carried out.

Hazards associated with road maintenance and operations include earthworks (i.e. grading), road watering and introduction of construction material (e.g. fill). Earthworks, including the construction of borrow pits, can potentially disturb natural drainage patterns, introduce or spread weeds, lead to soil erosion and result in the alteration of drainage lines or lead to the capture of water which in turn may attract animals and lead to an alteration in grazing patterns. Similarly introduction of fill material can result in alteration of drainage patterns and possibly introduction and/or spread of weeds. The presence of roads can also increase access by third parties to previously inaccessible sites.

Public roads will be maintained where impacted by Senex activities to minimise consequences on other public road users.

There are few hazards associated with road abandonment. Hazards include earthworks (i.e. ripping) and removal of road construction material (e.g. clay). Ripping can lead to soil erosion and alteration of drainage patterns. Disposal of road construction material may potentially spread weeds or alter drainage patterns and vegetation cover at the disposal site.



Table 22: Road construction and maintenance risk assessment


Earthworks and physical presence of road

Injury or death of fauna/stock in construction zone





Dust generation


Temporary disruption to land use (e.g. grazing and recreation)

Impeded fauna movement through construction zone





Use existing roads and tracks where possible

Minimise impact on the environment by appropriate route selection to minimise or avoid sensitive land systems, vegetation and cultural heritage sites or areas of high biological significance.

Observe procedures and guidelines for the identification, management and protection of cultural heritage sites including heritage clearances by Native Title groups

Design and construct road with drainage features (e.g. culverts and offtakes) that avoid disturbance to natural drainage and minimise erosion and sedimentation.

Undertake appropriate planning and construction for roads in floodplains and watercourses to avoid disturbance to natural drainage patterns. This may include: construction of roads at (or not significantly above) the natural surface

level as a minimum standard hydrological assessment of proposed roads and drainage features to

ensure potential impacts are identified and addressed in the design installation of culverts or bridges across channels or flow paths to

ensure flows are maintained installation of ‘fish passages’ to enable passage of fish and other

aquatic fauna where required consultation with relevant agencies (e.g. DSD, DEWNR, SAAL NRM

Board)



Avoid significant or priority12

vegetation and ensure proposed routes have been scouted for significant vegetation and wildlife habitats by appropriately trained and experienced personnel


Undertake environmental assessment and consultation with landowners and DSD regarding introduction of new road construction or stabilisation techniques or materials

Undertake vehicle and equipment washdown in accordance with the management strategy and using a risk–based approach before entering









Cooper Basin or after operating in areas of known weed infestations.




No blockage of any creek1 channels within the PEL182 Controlled Access

Zone (CAZ).


Movement of heavy machinery and vehicles along road and access tracks

Dust generation

Soil compaction

Soil erosion








Use existing cleared areas for laydowns and turn-arounds


Undertake vehicle and equipment washdown before entering Cooper Basin or after operating in areas of known weed infestations

Drive only on access tracks and road formation




Ignition of fire Disturbance to cultural heritage sites


Release of particulate emissions to the atmosphere


Smoking only in safe areas away from equipment or activity



Petrol vehicles to be excluded from construction sites

Emergency response procedures should contain a bushfire scenario




Spills or leaks associated with chemical and fuel


Access to contaminants by stock and

Implementation of appropriate chemical and fuel storage and handling procedures (e.g. bunding and signage, spill kits) in accordance with relevant standards, including AS1940, the EPA Bunding and Spill





storage and handling

wildlife Management Guidelines and the Australian Dangerous Goods Code (ADG)


Establishment of appropriate emergency/spill response procedures






Presence of borrow pits

Injury or death of stock and wildlife

Dispersal of watering points and redistribution of stock/wildlife movements resulting in inadvertent damage to vegetation and habitats

Soil erosion


Procedures for operation and restoration of borrow pits are followed

Existing unrestored borrow pits are used in preference to establishing new pits, and planning is undertaken to rationalise borrow pit establishment

Reworking of pits, or construction of new pits occurs a minimum of 75m from existing facilities, including stock yards

Pits are not to be established in locations which pose an unacceptable hazard to stock or wildlife

Where required bunds are installed to divert overland flow and prevent water ingress.


Restored pits have topsoil / overburden replaced and pit re-profiled where necessary to prevent erosion and minimise the capture of water


Movement of road construction material

Introduction and/or spread of weeds Inspect / monitor for weeds during standard inspections of facilities and infrastructure

Undertake control measures for weed outbreaks

Do not import material from areas of weed/disease infestation

Washdown of equipment bought in from high risk areas for weed





infestation.


Use of roads Dust generation


Injury or death of stock and wildlife


Training, speed restrictions and appropriate signage to reduce speed and increase awareness of hazards

Restrictions on night driving

Inspect / monitor for weeds during standard inspections

Signage to prevent unauthorised access





5.7 Aircraft Landing Area

The principal hazards associated with construction of an aircraft landing area are earthworks, vegetation clearance, chemical and fuel storage and waste disposal, as discussed for road construction in Section 5.6.

The major hazards associated with operation of an aircraft landing area are the storage of fuels and the disruption or injury to stock or wildlife, particularly birds. The area would be fenced to exclude stock or large fauna species.



Table 23: Aircraft landing area risk assessment


Earthworks See Road Construction and Maintenance above

See Road Construction and Maintenance above.

Take-off / landing of aircraft

Disturbance to stock and wildlife

Disturbance to landholders and the public

Injury or death of birds, stock or other wildlife

Airstrip will be located to minimise disturbance to landowners and the public.

Gates and signage installed to restrict vehicle and personnel movement through the landing strip area.

Area fenced to exclude cattle and large species of fauna.

Protocols implemented to ensure landing area is clear of stock or wildlife (e.g. pre-landing inspection)

Bird numbers monitored and scare methods used if large numbers become established on site.

Minor Unlikely Negligible (D2)

Leaks and/or spills associated with chemical and fuel storage and handling



If refuelling facilities are required, implementation of appropriate chemical and fuel storage and handling procedures (e.g. bunding and signage, spill kits) in accordance with relevant standards, including AS1940, the EPA Bunding and Spill Management Guidelines and the Australian Dangerous Goods Code (ADG)




5.8 Oil Transport (by Road)

The major hazard associated with the transport of oil on road networks is a leak or spill of oil or fuel (e.g. as a result of a collision or truck rollover). Many of the consequences associated with oil spills and leaks, such as vegetation loss, soil disturbance and drainage alteration can be minimised by effective emergency response and remediation. However, this largely depends on the land system involved.

Transport personnel will comply with road rules and drive to road conditions to minimise impact on other road users.

In dry environments, such as dunefields and gibber, the consequences associated with an oil spill are mainly localised, as oil is easier to contain and recover in dry conditions. However, the environmental consequences of oil spills in more sensitive wet environments, like the Cooper and Strzelecki Creeks and surrounding floodplains and wetlands, are potentially significant. Flood conditions that can potentially spread oil over large distances and throughout highly sensitive ecosystems are of primary concern and management measures need to minimise the environmental risk in these conditions.

Other hazards associated with oil transport include potential fire hazard, encountering stock or fauna on the roads. Consequences, such as stock or fauna death and vehicle damage or accidents, can be minimised by reducing the occurrence of night travelling and speed restrictions.



Table 24: Oil transport risk assessment

Hazard Consequence Management Strategy Consequence Likelihood Residual Risk

Use of roads See Road Construction and Maintenance above

See Road Construction and Maintenance above.

Spill associated with transport of oil / condensate (via truck) to land

Contamination of groundwater, surface water and soil



Transportation of chemicals, fuels and oils in accordance with ADG Code

Suitably trained, experienced and licensed contractors used to transport oil

Ensure roads and causeways are designed to minimise risk of vehicle accident

Regularly educate staff of product, review and monitor chemical and fuel transportation, including signage/labelling, proper packing and tie downs

Training and speed restrictions to reduce speed and increase awareness of hazards

Vehicles are maintained and serviced in accordance with manufacturer’s specifications

Avoid transportation movements in wet conditions

Appropriate communication between trucks and facilities to plan safe transport movements

Appropriate signage installed (e.g. at access to public roads)



Immediate clean-up and remediation to minimise contamination to soil/water





Spill associated with transport of oil / condensate (via truck) to watercourse / wetland

Contamination of groundwater, surface water and soil



As above, plus:

Install signage at creek crossings where appropriate

No fording of flowing streams

Removal of contaminated soil from spills in watercourses as appropriate

Call signs for traffic management at and along creek crossings and roads.




5.9 Waste Management

Waste at Senex production facilities is currently transported off-site to a licensed facility for recycling or disposal. Sewage and grey water is treated in approved septic treatment systems or aerobic treatment units on site and treated effluent irrigated to land. Untreated sewage is stored before being pumped out and trucked offsite by a licenced contractor. Concentrates from reverse osmosis / desalination would be disposed to ponds (e.g. produced water ponds if low volumes). There is a potential for localised contamination of soil and groundwater, as well as human health concerns as a result of leaks from the sewage treatment system or inappropriate disposal of treated effluent.

Senex does not currently operate landfill sites for disposal of domestic waste in South Australia. If landfill sites were required to be developed in the future, they would be sited in a suitable, stable area, distant from watercourses or floodplain areas and approved and operated in accordance with EPA requirements, as discussed in Section 3.8.1. In some circumstances, waste such as untreated wooden pallets or spacers from pipeline construction may be buried on site where recycling opportunities are not viable, provided specific approval has been obtained from EPA and DSD.

Senex do not currently have a land treatment area for the bioremediation and treatment of hydrocarbon contaminated soils due to the low volumes generated. In the future it is possible that Senex will need to establish a land treatment site for soil remediation, subject to necessary DSD and EPA approvals, as discussed in Section 3.8.3. A land treatment site would treat oily waste by mixing with existing soil, with the aim of breaking down oil by evaporation, photochemical processes and biological action of naturally occurring soil micro-organisms. Once hydrocarbons are broken down, soil would be transported by truck to an appropriate disposal location.

Potential consequences of these waste management practices include contamination or salinisation of soil or groundwater and the introduction and/or spread of weeds. In the case of a landfill site consequences also include outbreaks of pests and scavenging by wildlife.



Table 25: Waste management risk assessment


Storage of waste at camps or facilities and transport to landfill

Impacts to human health

Scavenging by native and pest species

Pest outbreaks

Localised contamination of soil and/or groundwater

Loss of visual amenity

Odorous emissions

EPA’s Waste Hierarchy model (avoid, reduce, reuse, recycle, recover, treat, dispose) complied with

Covered bins provided for the collection and storage of wastes. All loads of rubbish are covered during transport to an approved waste facility

Waste streams segregated on site and transported to appropriately licensed facilities to maximise waste recovery, reuse and recycling

Production of waste minimised by purchasing reusable, biodegradable or recyclable materials where practical

Hazardous wastes handled in accordance with relevant legislation and standards

Licensed contractors used for waste transport

Operational sites are kept free of litter and rubbish


Spills or leaks associated with disposal and treatment of sewage

Impacts to human health

Localised contamination of soil and/or groundwater


Containment of all untreated sewage wastes within septic tank or treatment system

Treated effluent irrigated to land or ponds in area with appropriate fencing / signage, in a location where it will not enter surface waters

Wastewater is disposed in accordance with South Australian Public Health (Wastewater) Regulations 2013 (disposal of wastewater must comply with the SA Health On-site Wastewater Systems Code or be operated to the satisfaction of the Department of Health) and the Environment Protection (Water Quality) Policy 2015.


Domestic waste disposal facility*



Scavenging by native animals and pest species

Pest outbreaks

Odorous emissions

Sited in a suitable, stable area, distant from watercourses or flood prone areas

Design and operation in accordance with EPA approval requirements

Undertake soil and groundwater monitoring

Cover and fence site with an appropriate material to prevent the spread of rubbish from the site by wind and prevent access by stock and wildlife

Bury rubbish immediately to facilitate degradation and reduce offensive odours and aesthetic consequences


Storage, treatment and disposal of contaminated soil*



Temporary storage of contaminated soil at Senex production facility in designated lined, bunded area in accordance with EPA guidelines prior to treatment or removal off-site by licensed regulated waste contractor to appropriately licensed facility for treatment or disposal

Appropriate siting of land treatment site in a suitable, stable area, distant from watercourses or floodplain areas

Design and operation in accordance with DSD / EPA requirements

Monitoring of surrounding soil and groundwater for contaminants at least annually

Fence off contaminated areas

Development of remediation plans for land treatment area


* Landfill and land treatment area activities do not currently occur but may in the future



5.10 Decommissioning / Rehabilitation

The major hazards associated with decommissioning are earthworks, movements of heavy vehicles, spills and leaks, chemical and fuel storage and waste disposal. Earthworks and vegetation clearance can potentially result in soil erosion, interruption of natural drainage patterns, disturbance to cultural heritage sites, introduction and spread of weeds and damage to vegetation, however the impacts are generally limited as earthworks are generally confined to disturbed infrastructure sites. Spills and leaks during decommissioning, waste disposal and chemical and fuel storage can lead to localised soil or water contamination.



Table 26: Decommissioning / rehabilitation risk assessment


Earthworks e.g. grading, ripping and backfilling

Injury or death of fauna in a construction zone




Disturbance to natural drainage patterns




Dust generation

Soil compaction


Earthworks restricted to the minimum area necessary (typically on existing, disturbed infrastructure sites)

Observe procedures for location of services and infrastructure

Obtain excavation permits where required

Observe procedures and guidelines for the identification, management and protection of cultural heritage sites

Liners are to be removed from ponds as soon as possible following the pond drying out to prevent liner deteriorating and creating litter problems.

Rip areas of compacted soil (except on gibber plains and tableland environments)

Respread topsoil and stockpiled vegetation

Restore natural contours to minimise impacts to natural drainage patterns

Minimise vegetation disturbance, and plan works to avoid vegetated areas and significant or “priority” vegetation

Stockpile any cleared vegetation and respread following works to facilitate revegetation

Minimise impacts to fauna by leaving excavations open for as little time as possible

Undertake vehicle and equipment washdown in accordance with the management strategy and using a risk–based approach before entering Cooper Basin or after operating in areas of known weed infestations



Movement of machinery and vehicles along ROW and access tracks during rehabilitation

Dust generation

Soil compaction

Soil erosion










Drive only on access tracks and pipeline easement






Spills and leaks associated with chemical and fuel storage and handling

Contamination of soil, groundwater and/or watercourses


Implement appropriate fuel and chemical storage and handling procedures (e.g. bunding and shut-off valves) in accordance with relevant standards, including AS 1940, the EPA Bunding and Spill Management Guidelines and the Australian Dangerous Goods (ADG) Code

Establish appropriate emergency/spill response procedures for spills or leaks to soil and water

Annual review and exercise of response equipment and procedures to ensure preparedness


Fence contaminated areas if threat is posed to stock or wildlife




Loss of containment of gas or oil (pipeline failure / pigging during decommissioning or leaks from facility equipment)







Abandonment programs planned to avoid or minimise hazardous situations, with controls in place to address risks

Pipeline decommissioning programs planned to take into account pipeline condition and location and minimise risk of rupture or leak

Establish appropriate emergency/spill response procedures for spills or leaks to soil and water

Annual review and exercise of response equipment and procedures


Fence contaminated areas if threat is posed to stock or wildlife



Disposal of hydrotest water or water used for flushing pipelines


Loss of vegetation and fauna habitat as a result of soil or water contamination

Use of biocides and toxic chemicals are kept to a minimum and where practicable biocides which degrade rapidly when exposed to UV shall be used

Disposal of water which contains biocide, other chemicals or hydrocarbons may be into existing lined and fenced evaporation ponds, or to specifically constructed lined pits sited to prevent the contamination of surface or near surface waters

Insignificant Unlikely Negligible (D1)

Explosion or fire at the facility or along the ROW


Abandonment programs planned to avoid or minimise hazardous situations, with controls in place to address risks

No smoking or safe smoking areas away from equipment or activity






Atmospheric pollution (gas)



Operation under fire permit requirements where relevant



Petrol vehicles to be excluded from gas well/pipeline sites

Establish appropriate emergency/spill response procedures for explosion or fire


Storage of waste and disposal to licensed landfill

Scavenging by native and pest species

Pest outbreaks


Minimise generation of waste where practicable

Recycle and re-use material where possible

Provide suitable covered bins for the collection and storage of wastes

All wastes are collected in designated area(s)

Cover all loads of rubbish leaving camps to ensure no spillage

Refer also to Table 25 for Waste Management




6 Environmental Management Framework

Senex is committed to conducting all its operations and activities in an environmentally sound and responsible manner. Senex will conduct its activities to ensure compliance with all applicable laws, regulations and standards and the protection of the environment from pollution and damage. Senex’s commitment is outlined in the Environmental Policy which is provided on the Senex website (www.senexenergy.com.au).

6.1 Environmental Management System

The Senex Environmental Management System (EMS) provides the framework within which Senex’s environmental responsibilities, issues and risks are managed. The EMS covers all activities undertaken by Senex in Australia including:

Petroleum exploration

Drilling and well operations

Petroleum production

The EMS is based on Australian Standard/New Zealand Standard ISO14001:2004 Environmental Management Systems – Requirements with Guidance for Use.

The Environmental Management System provides:

a framework for the environmental management of Senex’s exploration and production activities;

evidence of practical procedures to ensure that the environmental requirements are complied with;

contractors, administering authorities and the community with evidence that Senex’s operations are managed in an appropriate manner to comply with environmental objectives, approval conditions and other environmental regulations.

Senex’s EMS will continue to evolve in response to management reviews, changing technology, industry practices, regulatory requirements, research, monitoring and community expectations.

6.2 Planning

Senex plans and manages its activities in order to minimise disturbance to the environment in which it operates by utilising environmental standards consistent with development in technology, industry, codes of practice and all relevant statutory requirements.

Senex requires its employees and contractors to undertake their work in an environmentally sound manner and to consider environmental protection, and the protection of native flora and fauna in its operations, as one of their responsibilities.

The code of Environmental Practice of the Australian Petroleum Production and Exploration Association Ltd (APPEA) has been accepted by Senex as providing the most appropriate basis for its environmental management program. The basic principles adopted require the company to:

Comply with applicable Commonwealth and State Governments' statutory requirements for the protection of the environment;

In the absence of specific regulatory prescription or guidelines adopt the best practicable means available to minimise and ameliorate adverse environment impacts;

Consult with appropriate government agencies and other parties so as to meet all statutory requirements and to facilitate effective liaison with government and non- government bodies;

Ensure timely and effective consultation with landholders (owners or lessees) and where land is held or managed by Aboriginal communities ensure liaison is with relevant and authorised representatives;




Assess the regional and local environmental sensitivity and adopt strategies to avoid or protect such areas;

Plan to locate, design, operate and decommission all facilities and associated infrastructure so as to avoid or mitigate adverse environmental impact;

Monitor environmental effects and audit environmental performance at all stages of exploration, development and production; and

Provide adequate training to enable employees to recognise the potential implications of their activities and be equipped and motivated to act in an environmentally responsible manner.

6.3 Environmental Management Plans

A major component of the EMS are Environmental Management Plans (EMPs). Senex has either developed or adopted a number of EMPs to provide guideline and procedures on the environmental management of activities. EMPs currently in use by Senex are:

Environmental Management Plan for Drilling and Well Operations in the Cooper and Eromanga Basins, SA (Senex 2014)

Environmental Management Plan for Lignum 3D Seismic Survey (Senex, 2012)

Environmental Management Plan for Dundinna 3D Seismic Survey (Senex, 2012)

Environmental Management Plan for Seismic Operations in the Cooper and Eromanga Basins, SA (PIRSA 2003)

6.4 Environmental Induction

Environmental awareness training and inductions appropriate to the level of risk and type of work being performed will be provided to all employees, contractors and visitors. Training plans will be developed to attain, improve and maintain personnel competencies and the overall environmental performance of Senex.

The induction will specifically address the following environmental issues:

Environmental Policy commitments;

Health and Safety management;

Chemical storage and handling;

Weed and pest species management;

Organic certified properties;

Waste management;

Avoidance areas (e.g. heritage sites, lakes);

Erosion and sediment control;

Flora and fauna management;

Fire prevention;

Waste management;

Emergency response; and

Incident reporting (including spills, accidental discovery of cultural heritage).

6.5 Roles & Responsibilities

All Senex workers and contractors are responsible for the environmental performance of their activities and for complying with the general environmental duty as described in the EP Act 1994, Section 319(1) “a person must not carry out any activity that causes, or likely to cause environmental harm unless the person takes all reasonable and practical measures to prevent or minimise the harm”.



Pre-qualification assessment shall be undertaken to ensure that contractors have environmental management systems in place with the necessary environmental specifications and the general environmental duty provisions.

Key Senex personnel have specific environmental responsibilities when managing environmental management issues. These personnel and their responsibilities are presented below.

Senex

Licence-holder with overall responsibility for environmental compliance.

Ensure all workers are aware of the environmental obligations and Senex’s requirements and procedures.

Responsible for planning of production operations and approval by DSD.

Ensure compliance with SEO obligations and environmental procedures.

Environmental monitoring, reporting and corrective actions.

Development and implementation of management plans and procedures.

Provision of systems and resources to ensure compliance.

Undertake early and on-going contact with land owners/occupiers.

Report serious or reportable incidents to DSD and other government agencies / stakeholders if required.

Site Operators/Contractors

Responsible for ensuring compliance with Senex Environmental Policy, Environmental Procedures, Production Operations Manual and emergency response plan/procedures

Undertaking appropriate training and inductions

Responsible for complying with regulatory requirements, including any specific approval conditions

Report all incidents

Maintain ongoing liaison with Senex.

6.6 Environmental Procedures

Senex have adopted a number of Environmental Codes of Practice and environmental procedures to assist in the management of environmental consequences of their activities. These procedures include:

Environmental Procedures – Seismic Operations. Environmental Procedures for Seismic Exploration in the Cooper Basin, South Australia and Queensland (Santos 1999)

Environmental Procedures for Borrow Pit Management (Santos 1997)

Senex Cultural Heritage and Native Title Management Procedure (Senex 2016)

Stock Proof Fencing Standard (Santos March 2000)

Environmental Procedures for the Management of Aboriginal Heritage Sites (Santos 1998)

Code of Environmental Practice – Production and Processing (Santos 1999)

Code of Environmental Practice – Drilling and Workover Operations (Santos 1998)

Code of Environmental Practice – Seismic Operations (Santos 1999)

Field Guide to the Common Plants of the Cooper Basin, South Australia and Queensland (Santos 2003)

Australian Pipeline Industry - Code of Environmental Practice (APIA 2013)



Australian Petroleum Producers and Explorers Association Code of Environmental Practice (APPEA, 2008)

In addition, the environmental assessments carried out for each of Senex’s activities contain site specific procedures / requirements which must be followed.

6.7 Operations and Maintenance Policy

Senex’s Operations and Maintenance Policy details the core corporate requirements to achieve a safe system of operation and ensure legislative compliance arrangements are met and to mitigate HSE risks during the operation of Senex’s oil and gas fields.

The Policy links to other Senex policies, procedures and site-specific instructions by which Senex will operate and maintain field production facilities and pipelines systems safely, and in accordance with the requirements of Legislation, Australian Standards and Senex policies and procedures.



7 Consultation

The Cooper Basin is a sparsely populated and remote arid region. The local community broadly includes pastoral leaseholders, Innamincka township members, DEWNR personnel, tourists, petroleum explorers / producers, geothermal explorers and associated contractors.

It is a requirement under the Petroleum and Geothermal Energy Regulations 2013 that information on consultation with relevant landowners, Aboriginal groups or representatives, government departments or agencies, or any other interested person or parties be outlined in an EIR.

Petroleum production operations have been conducted in the region for over 30 years. Consequently, key stakeholders are aware of and understand the relevant issues associated with petroleum production operations in the Cooper Basin. Stakeholders in the Cooper Basin region include landholders and the local community, native title groups, regulatory agencies, industry groups and environmental organisations.

Senex’s operations (as Stuart Petroleum and Victoria Petroleum) were consulted on in the preparation of the EIRs that this document supersedes (see Section 1.1 and 1.3). Specific consultation with key stakeholders has been undertaken through circulation of the EIR and SEO. Consultation with several government agencies (principally DSD, DEWNR and EPA) was undertaken on selected issues during the development of this EIR.

Further to this extensive consultation with stakeholders was undertaken by Senex and DSD during production and review of Senex’s Cooper Basin Petroleum Production Operations EIR and SEO in 2014 and Senex’s PEL 182 Drilling, Completions and Well Operation SEO and EIR (2016).

Senex maintains ongoing contact with landholders in relation to all aspects of its operations in the Cooper Basin.

Senex aims to continue to engage stakeholders for the duration of its production activities to ensure that all potential concerns are identified and appropriately addressed.

Effective consultation allows for an exchange of information and provides an opportunity to promote understanding and resolution of competing interests.

7.1 Key Stakeholder Consultation

Senex Energy is committed to maintaining effective communication and good relations with all stakeholders. Senex Energy has been undertaking a program of consultation with directly affected parties and other stakeholders, as outlined below. Issues raised to date have been integrated into this report where relevant.

Key stakeholders were provide the opportunity to submit any comments on the EIR and SEO prior to formal submission to DSD (refer to Table 27). Comments received during the consultation period are provided in Table 28 below.

Table 27: Stakeholder consultation list

Government

Environment Protection Authority (EPA)

Department of Environment, Water and Natural Resources (DEWNR)

SA Arid Lands Natural Resources Management Board

Aboriginal Affairs and Reconciliation (AAR)

Department of Planning, Transport and Infrastructure (DPTI)

Outback Communities Authority

Lake Eyre Basin Community Advisory Committee

Cooper Creek Catchment Committee



Non-Government

Conservation Council of SA

Innamincka Progress Association

Wilderness Society

Yandruwandha Yawarrawarrka Traditional Land Owners (Aboriginal Corporation)

The Dieri Aboriginal Corporation RNTBC

Wangkangurru Yarluyandi Native Title Claimant

South Australian Chamber of Mines & Energy

Landholders

Alton Downs

Andrewilla

Beckwith

Bollards Lagoon

Clifton Hills

Cordillo Downs

Dickinna

Gidgealpa

Goyders Lagoon

Innamincka

Kanowanna

Lake Hope

Lindon

Merty Merty

Pandie Pandie

Innamincka & Strzelecki Regional Reserves

Industry

Crossland Mines Pty Ltd

TC Development Corporation Pty Ltd

Lakeway Resources Pty Ltd

Pacific Hydro Pty Ltd

Clean Energy Australasia Pty Ltd

Geodynamics Ltd

Santos Ltd

Epic Energy Pty Ltd

APA Group

Beach Energy Ltd

Drillsearch Energy Ltd

Strike Energy Ltd

Cooper Energy Ltd

Linc Energy Ltd

Terra Nova Energy Ltd



Table 28: Comments submitted during 2014 stakeholder consultation

Agency/

Stakeholder Section Comment Response

Conservation Council

General Greater detail on how Senex is approaching on ground challenges Comment noted.


General Tangible data in relation to [Senex’s] environmental performance. Comment noted and further addressed in the responses provided below.


General SEO reporting informs and meets the needs and expectations of the wider community

Comment noted.

EPA General Camp Sites – waste generation at well sites and associated camps should comply with the EPA waste Hierarchy model (avoid, reduce, reuse, recycle, recover, treat, dispose). Waste materials should be segregated to maximise the ability to recycle. Containers subject to deposit legislation and other recyclables should be segregated and transferred to a licensed waste transfer facility. Clean paper and cardboard should also be managed in this manner.

All other materials, including putrescible waste, must be collected, segregated and disposed of at an EPA licensed facility licensed to accept the waste.

Comments noted. EIR Section 5.9 and SEO Section 3 Table Objective 11.

Senex also operates under the Senex Waste Management Procedure – Operations which ensures that waste generated at Senex operations is compliant with EPA licensed facility requirements, regulatory requirements and EPA environmental standards.

This includes:

Waste stream characterisation and segregation;

Assessment of waste reduction opportunities for identified waste;

Management of waste in accordance with the waste management hierarchy; and

ensuring wastes and recyclable materials are transferred to EPA licensed facilities.

Small camp sites, itinerant and isolated locations – The disposal of waste material such as paper, cardboard and food scraps via burning is not desirable. Rather this material should be buried at an appropriate location and depth (as is reasonably practicable) in order to prevent exposure of waste by fauna or wind/water erosion. Once covered, the site should also be compacted to further minimise the risk of future exposure.

EPA General The EPA is supportive of dust management and control actions and suggest both waterless and water efficient techniques be utilised.

Comment noted and Senex will investigate options and opportunities for utilising waterless and water efficient techniques.

EPA General Fuels and chemicals should be stored in compliance with EPA Guideline 080/12 Bunding and Spill Management (august 2012). A copy of the guideline can be obtained from www.epa.sa.gov.au/xstd_files/Waste/Guideline/guide_bunding.pdf

Appropriate staff and contractors must receive adequate training in the use of spill response equipment to ensure spills are managed appropriately.

Comment noted. SEO Section 3 Table Objective 3 states that all fuel, oil and chemicals are stored, handled and transported in accordance with appropriate standards and guidelines e.g. AS 1940, EPA requirements and Australian Dangerous Goods Code.

Further to this Senex ensures that training is completed in Hazardous Substances and Dangerous Goods requirements through the Hazardous Substances and Dangerous Goods online training module provided through the Senex training portal. Additional site specific

http://www.epa.sa.gov.au/xstd_files/Waste/Guideline/guide_bunding.pdf



requirements and hazards are communicated via the site specific (Level 2) Induction process in place at each Senex work site.

Familiarity with, and training in, spill response techniques is provided by the conduct of regular Spill Response Drills conducted as a component of the Senex Emergency Response system, drills and audits of spill response equipment are scheduled via the Field HSE Task Schedule and facilitated by the Senex Field HSE Advisor.

EPA General Turkeys nest – Where a turkey’s nest is proposed, the following construction details are required to be met:

High density polyethylene (HDPE) liner with a minimum thickness of 2mm is preferred where highly saline water or water containing chemical additives are stored in the turkey’s nest; or

A 300mm compacted clay liner with a permeability of 1x10-

9metres/second; or

Another appropriate methodology where the applicant can demonstrate that risk of environmental harm is low.

Senex does not routinely construct turkey’s nest dams as part of production activities however in some cases the turkey’s nest constructed for drilling water may be retained for use during production operations.

All turkey’s nest dams constructed on Senex operational sites are lined with a 0.3mm liner and hold only fresh water used for drilling operations. Turkey’s nest dams are typically not dosed with chemicals and the water quality is low salinity suitable for drilling use. In the event that

highly saline water (EC >5,000S/cm) or water containing chemical additives is stored in a turkeys nest the outlined EPA construction requirements will be met.

Initial restoration – if chemicals are proposed to be added to Turkey’s nest water, the proponent should ensure during restoration works any remaining waters are allowed to evaporate and any residues removed by a licensed waste contractor prior to recovery of the liner (assuming the liner is HDPE or similar).

Comment noted.

EPA General Formation water – The proponent must ensure that formation water requiring disposal does not enter the natural water courses, ground water aquifers/lenses and other environmentally sensitive areas.

SEO Section 3, Table 1 Objective 3 addresses the management and control of produced formation water.

EPA General Blasting – should blasting be required near any buildings or structures, the owner or occupiers should be provided with adequate notice of the frequency and duration of such activity.

Comment noted.

EPA General Proponents must be aware of their requirements under the Environment Protection (Noise) Policy 2007, particularly when undertaking activities within

close proximity to sensitive receptors.

Comment noted.

DSD-AARD General - Ongoing exploration drilling

Prior to commencing any future exploration drilling it is recommended that [Senex] identify the relevant coordinates and forward these to DSD-AARD with a request to search the Register.

Comment noted and Senex agrees to submit requests for a search of the Register for exploration drilling. Note this is typically completed as part of Work Area Clearance processes.



DSD-AARD General - Aboriginal Heritage Act 1988

Pursuant to the Act, it is an offence to damage, disturb or interfere with any Aboriginal site or damage any Aboriginal object (registered or not) without the authority of the Minister for Aboriginal Affairs and Reconciliation. If the planned activity is likely to damage, disturb or interfere with a site or object, authorisation must first be obtained from the Minister under Section 23 of the Act.

Comment noted. Senex also provides the following additional points:

1. In some instances under Section 23 the Minister has delegated

authorisation to the Traditional Owner Groups.

2. Under Section 20 the decision on reporting sites and objects of

cultural heritage significance is left to the discretion of the

Traditional Owner Group as there are cases where the Group has

not wanted this knowledge reported.

3. Senex, as part of the site heritage clearance process, is only

provided with a basic level of information regarding discoveries on

the land necessary to avoid or protect a location. Senex consider

it is more appropriate for the Traditional Owner Group to report

matters relating to Aboriginal sites, objects or remains according

to their customs and beliefs.

Section 20 of the Act requires that any Aboriginal sites, objects or remains, discovered on the land, need to be reported to the Minister. Penalties apply for failure to comply with the Act.

References throughout the EIR document such as in Table 1 on page 7 to ‘relics’ being destroyed should be reframed to the language of Section 23 of the Act, i.e. damage, disturb of interfere with Aboriginal sites, objects or remains.

Comment noted and relevant sections corrected.

DSD-AARD General -Consultation with Traditional Owners

To assist with clarity, the document should clearly identify the Aboriginal heritage body or nominated representatives Senex is working with to protect the Aboriginal heritage in the project area.

Section 4.7.3 Table 10 identifies the Native Title claims and the representatives Senex is working with in the project area.

[AARDs] reading of objective 10 of the SEO is that consultation with stakeholders in relation to the possible existence of heritage sites will only take place as necessary and that sites would be examined by the relevant native title group only in those areas not previously cleared. It would be worthwhile considering that consultation should be fit for purpose and relying upon previous consultation, while may be useful in providing an indication of heritage in the area, may not provide a full understanding of the heritage issues in relation to your specific activities.

It is standard practice that where a WAC is over 2 years old, and no activities have been carried out on the WAC area during those 2 years, Senex will consult with the Traditional Owners as to whether a new clearance is required. If the Traditional Owners assess that a new clearance is required, a further WAC will be conducted.

In addition, a new WAC will be conducted wherever the activities contemplated in the original WAC have changed, unless advised otherwise by the Traditional Owners.

Early engagement with the Traditional Owners is recommended. If this is In response Senex provides the following additional information



already the case the wording could be changed to better reflect the established relationships and protocols.

regarding consultation with Traditional Owners.

Senex has consulted and worked closely with the Traditional Owners over many years of operations in the project area. Prior to any work being conducted on Senex tenements, the relevant Aboriginal heritage body concerned is identified.

Under Cultural Heritage Agreements and determinations and in consultation with the relevant Aboriginal party, the following strategies are in place to avoid disturbance to sites of cultural heritage significance:

Prior to Project Development -

a. Work Area Clearances are conducted with a team of relevant Traditional Owners together with their Technical Advisors (Archaeologists / Cultural Heritage Specialists) of the proposed project area.

b. Objects and sites of Cultural Heritage significance are recorded with GPS locations together with descriptions of no-go or exclusion zones.

c. Mitigated items and their original locations are also recorded and mapped.

During Construction -

a. Before construction commences, pegs are placed around the sites in question indicating the extent of the no-go zones.

b. Site inductions are held to advise field crew of exclusions zones and areas to avoid

c. If required, under the terms of any agreements and in consultation with the respective Traditional Owners arrangements to have monitors on site during construction.

d. Protocols and training, in consultation with Traditional Owners, on what actions, if any CH item are located during the construction process.

After Construction -

a. In consultation with Traditional Owners removal of all pegs unless required for on-going operations

b. Rehabilitation of Cultural Landscape

c. Traditional Owners to return any objects removed or relocated



as during activities to “Country”.

DSD-AARD It should be noted that it is also possible for people from other Aboriginal communities to have affiliations with an Aboriginal site that is outside of their Native Title claim area.

Senex notes that there may be other Aboriginal communities involved in the Native Title claim area.

Please be aware that the Minister for Aboriginal Affairs and Reconciliation has delegated his powers under section 21, 23, 29 and 35 of the Aboriginal Heritage Act to the Yandruwandha Yawarrawarrka Traditional Land Owner Aboriginal Corporation (YYLTOAC) in relation to all Aboriginal sites, objects, remains and traditions that relate to, originate from or are within the same external boundary of the Yandruwandha Yawarrawarrka Native Title claim (SAD6024/98).

Should your company seek an authorisation under any of these sections of the Act in the delegation area, YYTLOAC will undertake the required consultation process and decision making under the Act. In all other areas of the Cooper Basin Petroleum Production Operations the Minister has retained his decision making authority.

We acknowledge that the Minister for Aboriginal Affairs and Reconciliation has delegated his powers under section 21, 23, 29 and 35 of the Aboriginal Heritage Act to the YYTLOAC in relation to all Aboriginal sites, objects, remains and traditions that relate to or are within the same external boundary of the YY Native Title claim (SAD6024/98)

DSD-AARD General -Discovery Protocol

DSD-AARD has a protocol for the discovery of Aboriginal heritage for proponents working areas where there is a risk of discovering Aboriginal sites or objects. DSD-AARD recommends that Senex Energy Ltd considers adopting the DPC-AARD Protocol for the Discovery of Aboriginal skeletal remains and if a section 23 authorisation is sought and granted, the associated Protocol for Discovery of Sites and Objects.

In accordance with Aboriginal Cultural Act 1988 and Enironment Standards and Guidelines – Managing the Discovery and Treatment of Skeletal Remains a protocol is being developed which takes into consideration the DPC-AARD flowcharts but essentially the protocol applied is as follows:

Work is to stop immediately

Site Supervisor/Project Manager to be alerted

The Police are to be notified

The remains are to be forensically determined (ie human / crime site / Indigenous)

If Aboriginal, DPTI EO to be contacted who will in turn contact the Aboriginal Groups connected

Work can only recommence following agreed treatment of remains dependent on whether with or without a Section 23 Authorisiation.

Conservation EIR Section Additional context on the role of the EIR, explaining that under Section 10 of the P&G Regs 2013 that the report must describe matters including

Additional paragraph inserted in Section 1.3.1 providing context of the role of the EIR and matters that must be described under section 97 of



Council 1.3.1 regulated activities to be carried out, foreseeable events. Information on the estimated frequency of those events, and the potential consequences of these events.

Should also explain that the EIR is also to be updated on a 5 yearly basis.

the P&G Act 2000 is addressed in detail in Section 2.1.

Under section 14 of the Regulations an approved SEO must be reviewed at least once in every 5 years.

The context could also provide a short description of the role of the SEO and to annual performance reporting documents.

Paragraph included in Section 1.3 to provide a short description of the role of the SEO and requirements for annual performance reporting.

EPA EIR Section 2.2

The Radiation Protection and Control Act 1982 should be incorporated. The requirements of the Radiation Protection and Control Act 1983 have been incorporated into Section 2.2 Table 1.

EPA EIR Section 3.2.1

Infiltration systems as outlined in Section 3.2.1 for wastewater containing petroleum products (or any Part 1, Schedule 4 pollutant) are not compliant with the Environment Protection (Water Quality) Policy 2003. It is noted

however that infiltration systems are not covered, or proposed in this particular SEO.

Comment noted.

EPA EIR Section 3.2

In addition to ensuring hydrocarbon values are within appropriate range, other analytes must be considered and tested to demonstrate compliance with the maximum values for the intended use (e.g. irrigation and livestock watering).

All Senex ponds are routinely tested for the following parameters: Major Cations, hardness, pH, Major Anions, Conductivity, calculated Total Dissolved Solids, Nitrate, Resistivity, Total Petroleum Hydrocarbons, Total Recoverable Hydrocarbons, BTEX and PAH.

Where required (e.g. for supply to livestock) additional parameters are tested including colour, Total Suspended Solids, turbidity and standard Total Dissolved Solids.


Clause 17 of the Environment Protection (Water Quality) Policy 2003 is the

relevant Clause for sewage (Part 1, Schedule 4 pollutant). Noted and corrected.


The EPA considers that a spill remediation approach should be selected based on volume, estimated horizontal and vertical impact and the environmental sensitivity of the impacted environment. The assessment for uncontained spills with a larger scale impact (potentially non-trivial) should be undertaken in accordance with the National Environment Protection (Assessment of Site Contamination) Measure (1999) amended in 2013 and relevant SA EPA Guidelines.

Noted and additional wording included in Section 3.8.3 to address.

The establishment of a land treatment farm for soil remediation (for Senex’s own contaminated soil) should be undertaken in line with the relevant EPA guidelines, including the EPA Guideline “Environmental Management of On-

Noted and additional wording included in Section 3.8.3 to address.



site Remediation” 2008. The EPA also notes that any proposal submitted for approval relating to a land treatment area for bioremediation should take into account a number of factors, including volume of contaminated soil, type of contamination, methodology, active ingredient, pre and post treatment concentrations, base liner design (to ensure permeability) and re-use options on-site.


EIR Section 3

Description of Production Operations – scope for improvement to include the oversight, management, assessment, monitoring and reporting of GGE. As a major fossil fuel industry participant we believe that the GHG aspects of Senex’s activities should be integrated into this SEO.

Senex currently reports annually under the National Greenhouse and Energy Reporting Act 2007 (NGER) and has done so since the 2009-10 reporting period. Greenhouse gas emissions in all previous reporting periods have been well under the facility threshold trigger for public reporting.

Senex has also been reporting to the National Pollutant Inventory (NPI) since the 2011-12 reporting period.

Senex will continue to report in compliance with the requirements of NGER and NPI.


EIR Section 4

Senex does not identify that the public are legitimate stakeholders that have an interest in the reporting of progress towards environmental objectives.

Public access to environmental data required under the P&G Act, including reporting under the SEO, is available on the Department of State Development (DSD formerly DMITRE) website at the following link :

http://www.pir.sa.gov.au/petroleum/environment/register

Senex currently provides reporting on environmental and sustainability performance in the Company Annual Reports and Annual Licence Compliance Reports (available on the DSA register) which are aimed at public and community stakeholders.

Senex recognises the importance of reporting against environmental progress and performance and commits to expanding the company annual reporting commencing 2014-2015 reporting period to provide more detailed information and data on the environmental, social and governance aspects.

Senex does not describe how progress towards the achievement of environmental objectives will be communicated to the public on an annual basis. Will it be a single report that relates to this SEO, or will it be contained in reporting for individual licences? When will progress updates be available? How will reports be accessible?


EIR Section 5

The EIR does not provide baseline of current information on the frequency of events that cause environmental impacts, nor does it describe any information on the consequences of events, the size and scope of consequences experienced to date or cumulative impacts.

The risk assessment was carried out by an independent consultant (RPS) and Senex, based on knowledge of the existing environment, and experience with production operations in the Cooper Basin undertaken by both Senex and other companies (e.g. Beach Energy and Santos). Consequences of events are described in the tables




associated with each activity (e.g. EIR Table 18 Consequences associated with earthworks in various Cooper Basin landforms). The risk assessment process has taken into consideration Senex and other operators experience in the Cooper Basin to date, the potential consequences of events and the potential for cumulative impacts.


EIR Section 5

The Risk Assessment presents a column for potential consequences as if this was an entirely new project or activity. However petroleum resource activities described in the EIR are a continuation of long standing activities and for this reason we believe that the EIR should also be showing a column containing current impacts and information, including a wide range of data and reporting that would be expected in the most recent environmental performance reports.

The risk assessment is based on the likelihood and consequences of environmental harm occurring from an activity and has taken into consideration the potential for impacts from existing activities. It has also been developed based on knowledge and experience of Senex’s production operations and those of other operators.

Senex’s production activities have been, and continue to be, carefully managed to control and prevent environmental impacts and to date there have been very minimal impacts relating to Senex’s production operations to include in the suggested ‘current impacts column’.


EIR Section 5

The EIR appears to convey a hypothetical environmental impact assessment rather than an Environmental Impact Report that consolidates and updates information based on actual performance data.

The EIR provides a hypothetical assessment of the likely impact of production activities on the environment and builds on Senex and other operator’s experience and knowledge including actual environmental performance.


SEO Section 1

SEO is highly generic and covers mostly reference to procedures that are meant to avoid or minimise environmental impacts. It does not provide a sound basis to underpin continuous improvement or a direction to improve sustainability of Senex.

This Statement of Environmental Objectives (SEO) has been prepared to meet the requirements of Sections 99 and 100 of the South Australian Petroleum and Geothermal Energy Act 2000 (the Act) and Regulations 12 and 13 of the Petroleum and Geothermal Regulations 2000 (the Regulations).

[SEO] does not include outcome based objectives that could be identified through specific, measurable, achievable and realistic, to be achieved in a given timeframe (SMART targets)

The assessment criteria presented in the SEO and further detailed in the EIR are consistent with the requirements under Section 100 of the P&G Act.


SEO Section 1.2

Describes the scope of the document in relation to legislative requirements only. A capacity for Senex to demonstrate best practice environment and sustainability performance would be improved if the SEO was also aimed towards public and community stakeholders that have a strong interest in the activities of Senex.

Senex provides reporting on environmental and sustainability performance in the Senex annual report which is aimed at public and community stakeholders.

Senex recognises the importance of reporting against environmental progress and performance and commits to expanding the company annual reporting commencing 2013-2014 reporting period to provide more detailed information and data on the environmental, social and



governance aspects.

DEWNR SEO Section 3 Table 1 Objective 1

Dot Point: ‘Appropriate firebreaks are maintained’. DEWNR recommends further emphasis of this dot point. It is recommended the dot point be amended to: ‘Appropriate firebreaks (such as adequate earth breaks around camps and infrastructure) are maintained’.

Additional wording including in Section 3, Table 1 Objective 1.


‘Ponds and dams are fenced to prevent fauna and wildlife access’. DEWNR recommends further emphasis of this dot point. It is recommended that the dot point be amended to:

‘Ponds and dams are fenced to prevent fauna and wildlife access and escape ladders are installed on each pond and dam’.

Comment noted. Senex monitoring has shown wildlife entrapment within surface water ponds is extremely rare with no occurrences since record keeping began in 2012. Where an issue with fauna egress from a pond arises Senex will investigate opportunities for managing access to the ponds, this may include trialling escape ladders, small fauna fencing or other options.


Suggest providing further information about weed infestations and control options. It is recommended that the following sentence be inserted at the end of the last paragraph:

‘Consult with the Senior Ranger, Innamincka, regarding weed infestations and control options’.

Additional wording included in Section 3 Table 1 Objective 5.


DEWNR recommends further emphasis of the design and construction of access tracks and roads in the regional reserves.

‘Prior to track or road construction, consult with the Senior Ranger, Innamincka, regarding design specifications to avoid tracks and roads being graded down and forming additional drainage lines in the future.

Additional wording included in Section 3 Table 1 Objective 6.

EPA SEO Section 3 Table 1

It is noted that an oil spill contingency plan (Objective 3, Page 10) states that an oil spill contingency plan, in accordance with “Regulation 31” is required. The preparation, implementation and management of a contingency plan for oil spills is supported by the EPA, Any oil spill contingency plan, subsequent remedial action (including clean-up) should be undertaken in accordance with the National Environmental Protection (Assessment of Site Contamination) Measure (1999) amended in 2013 and relevant SA EPA guidelines.

Noted and additional wording included in Section 3, Table 1 Objective 3 to address.

It is noted that per Objective 3, Page 12 that there are a number of objectives relating to siting of the ponds, design criteria, operation, maintenance and water quality. The requirement for of these aspects must comply with the requirements of the Environment Protection Act 1993,




including the Environment Protection (Water Quality) Policy 2003, the conditions of any SA EPA Authorisations, and the EPA Guideline Wastewater and Evaporation Lagoon Construction. A copy of the current

guideline can be obtained from www.epa.sa.gov.au/pdfs/guide_lagoon.pdf

Objective 6, Page 17 outlines there will be no “unlicensed discharge of water to waterways”. An EPA Authorisation may apply to this activity. If so, the EPA will assess compliance against the conditions of the Authorisation and relevant regulations under the Environment Protection Act 1993.


EPA SEO Section 4.3

In order to report an incident in line with Section 83 of the Environment Protection Act 1993, the EPA emergency phone number is 1800 100 833. The secondary number (if the first emergency number is not available) is 08 8204 2004. These details should be incorporated into this document.

It is also noted that two exemptions from the Environment Protection Act 1993 are mentioned in this section. In relation to the second exemption, please note and correct the wording of Section 7(4)b of the Environment Protection Act 1993, i.e. the Act does not apply to:

“Wastes produced in the course of an activity (not being a prescribed activity of environmental significance) authorised by a lease or licence under the….Petroleum [& Geothermal Energy] Act 2000…when produced and disposed of to land and contained within the area of the lease or licence”.

Noted and wording of Section 4.3 dot point two corrected to include the word ‘lease’.


SEO Section 4

[Conservation Council] have considered the information on environmental performance provided in the Senex Annual Report and have found that it is too brief to inform of progress towards environmental objectives.

Senex recognises the importance of reporting against environmental progress and performance and commits to expanding the company annual reporting commencing 2014-2015 reporting period to provide additional detailed information and data on the environmental, social and governance aspects.

Reporting against the SEO objectives is provided in the Annual Licence Compliance Reports which are available on the DSD website at the following link :


It is strongly suggested that this section be enhanced to include all aspects of public reporting, including information and web links to assist the community to access annual environmental performance / compliance

Public access to environmental data required under the P&G Act, including reporting under the SEO, is available on the Department of State Development (DSD formerly DMITRE) website at the following

http://www.epa.sa.gov.au/pdfs/guide_lagoon.pdf




reports via the Senex and DMITRE websites. link :


Senex prepares Annual Licence Compliance Reports against SEO objectives (available on the DSA register) which are aimed at public and community stakeholders.

Senex also provides reporting on environmental and sustainability performance in the Company Annual Reports available at:


[Conservation Council] believe that basic data is an essential part of future EIR’s. Best practice environmental report from many sectors include quantitative data on:

Fuels use

Electricity use

Greenhouse gas emissions (scope 1, scope 2 and significant scope 3 emissions) including approaches to assessing landscape and infrastructure fugitive gas emissions

Major chemical use

Environmental incidents (major and minor) and some level of discussion around what went wrong, what was learnt and whether the risk of reoccurrence has been adequately reduced ([Conservation Council] understand that Section 32 of the Regulations covers much of this work, and seek that performance and progress is also communicated to public stakeholders)

Activities and initiatives taken to address issues such as weeds and feral pests, sustainability initiatives (including some expenditure in relation to major initiatives)

Achievements against environmental and sustainability targets such as for renewable energy generation or use

Fauna entrapments, particularly those that result in injury or death and repeat incidents

Senex will be expanding the company annual reporting commencing 2014-2015 reporting period to provide additional quantitative data including reporting on energy use, environmental activities and initiatives, achievements against renewable energy generation and environmental incidents.

Some of the requested items of quantitative data are currently reported annually in various forms and are publicly available including:

Senex Annual Company Reporting

Annual Licence Compliance Reports (which includes incident and non-compliance reporting)

NPI reporting (emissions reported by substance and /or facility)


SEO Section 3

[Conservation Council] recommend that the SEO describes the framework of measures, performance data and in some cases, targets for commitments that will be used to quantify success.

Senex works towards the framework of measures, performance data and targets required against the DSDs Goal Attainment Scoring (GAS) criteria relevant to production operations.

Conservation SEO Section It is worth noting that whilst information is already collected by Senex Senex has been reporting annually under the National Greenhouse and





Council 3 - Greenhouse Gas Emissions

towards the NGER process, this information is not available to the public. Energy Reporting Act 2007 (NGER) since the 2009-10 reporting period. Senex’s greenhouse gas emissions in all previous reporting periods have been well under the facility thresholds. NGER data is only

published if the threshold of 50 kilotonnes CO2-e is triggered and to date Senex has not reached this threshold.

Senex has also been reporting to the National Pollutant Inventory (NPI) since the 2011-12 reporting period.


NPI data is available publicly through the database kept by the Department of Environment. Senex 2012/2013 reporting data is available at:

http://www.npi.gov.au/npidata/action/load/summary-result/criteria/reg-business-name/SENEX%2BENERGY%2BLIMITED/destination/ALL/source-type/INDUSTRY/substance-name/All/facility/SENEX%2BENERGY%2BLIMITED/subthreshold-data/Yes/year/2013

[Conservation Council] believe that the comprehensive coverage of monitoring and reporting greenhouse emissions from both infrastructure and landscape leakage is best covered under the operational SEO which can incorporate the broad range of emission sources from wells, pipelines and other facilities used in operations.

Greenhouse gas emissions reporting items requested are covered by annual reporting requirements under the National Greenhouse and Energy Reporting Act 2007 (NGER) and the National Pollutant Inventory (NPI).


The Conservation Council SA has suggested a template to show the basic level of GHG emissions that would be relevant to gas and oil production of Senex in the Cooper Basin (submission Appendix 1).

Senex’s reporting of greenhouse gas emissions are consistent with the statutory reporting requirements under the National Greenhouse and Energy Reporting Act 2007 (NGER) and the National Pollutant Inventory (NPI).


SEO Section 3 – Environmental Commitment

The proposed SEO does not provide any significant goals and targets that it would strive to achieve for greater environmental protection and sustainability.

Senex is committed to ensuring production operations are conducted in an environmentally responsible manner and is consistently working to achieve greater environmental protection and sustainability.

This Statement of Environmental Objectives (SEO) has been prepared to meet the requirements of Sections 99 and 100 of the South









s Australian Petroleum and Geothermal Energy Act 2000 (the Act) and Regulations 12 and 13 of the Petroleum and Geothermal Regulations 2000 (the Regulations).

The thirteen listed Environmental Objectives…do not convey a sense of commitment to improving environmental performance of to contribute to the sustainability of South Australia.

To enhance the proposed SEO it is suggested that the thirteen process based environmental objectives be supplemented with some strategic outcome based goals, targets and projects designed to guide the environmental performance of Senex to a position where it can demonstrate best practice without question.

Potential areas of interest include:

Pest and weed management

Fauna protection and recovery

Habitat protection and management

Water protection and management

Recycling and waste management

Greenhouse gas mitigation and renewable energy

Commitments, reporting and accountability

Comment noted.

Senex is committed to complying and where practicable exceeding the requirements of the P&G Act and all other relevant legislation and regulations imposed upon it by South Australian and Federal regulatory agencies.


SEO Section 3 – Best Practice Fauna Management

No data on fauna entrapments is publically provided by Senex so it is impossible to know whether performance in this area is good or poor.

Comment noted. Senex monitoring has shown fauna entrapment within surface water ponds is extremely rare with no occurrences since record keeping began in 2012.

In areas such as the fencing of surface water ponds, there is no detail on the standard of fencing of what size fauna is excluded.

Active Senex wellsites and facilities are fenced to exclude unauthorised personnel, stock and medium to large fauna. Within these fenced sites, surface water ponds are also fenced to exclude stock and medium to large fauna. Senex personnel monitor these facilities regularly. Freeform evaporation ponds that extend over larger areas outside of facility and wellsites are also fenced to exclude stock and medium to large fauna.

The SEO also makes no mention of escape ramps on surface water ponds. Senex personnel conduct regular monitoring of surface water ponds for the presence of fauna. This monitoring has observed fauna entrapment within Senex surface water ponds to be a very rare event.



The document refers to the risk to birds coming into contact or ingesting hydrocarbons (oils) but no quantification on the extent of this risk is provided in the proposed SEO and no data on fauna entrapment is provided to DMITRE or the public.

Senex surface water ponds are generally of good quality and contain limited amounts of hydrocarbons due to their removal during production processing. Interceptor and evaporation ponds are regularly skimmed to remove any surface hydrocarbon film. Regular water quality monitoring of Senex surface water ponds indicates hydrocarbon levels are compliant with EPA and DMITRE regulations. No bird entrapment or deaths have been noted at Senex sites since record keeping began in 2012.


SEO Section 3 – Liquid Storage Ponds

The Conservation Council is concerned at the number of clay lined storage facilities that leak. We would recommend a commitment for storage facilities to be fitted with impervious polymer linings in addition to clay linings to reduce the likelihood of liquid storages leaking contaminated fluids into the ground.

Water storage facilities are designed, operated and monitored in accordance with facility approval conditions, provisions of the Environmental Protection Act 1993 and requirements under the Environmental Protection (Water) Policy 2003.

Interceptor ponds are appropriately lined with an impermeable liner in addition to clay liner to reduce the likelihood of leakage to groundwater.

Senex water management systems operate to maintain hydrocarbon concentrations within the required limits. For bunded evaporation ponds the levels are below 30mg/L and freeform evaporation ponds levels are below <10mg/L.

[Conservation Council] would also encourage that there be monitoring for leaks beneath wastewater ponds, evaporation ponds and similar infrastructure, together with annual public reporting the frequency of leaks found and extent of any leakage.

Where deliberate infiltration systems are used, there should be meaningful description on the number of such facilities and the standard of water quality that is achieved prior to fluids being disposed of in this way.

DSD-AARD Section 3.1 Page 12

Table 2

The EIR document identifies a list of Senex production facilities. AARD advise that the Central Archive, which includes a Register of Aboriginal Sites and Objects, administered by DSD-AARD has entries for Aboriginal sites within tenements in PEL 104 and 115. The Central Archive has numerous entries for Aboriginal sites, but not all sites in South Australia are recorded. Further sites or objects may exist in the proposed development area. All Aboriginal sites and objects are protected under the Act, whether they are listed in the Register or not. Land within 200m of a watercourse in particular, may contain Aboriginal sites and objects.

Comment noted.



Table 29: Comments submitted during 2016 stakeholder consultation

Agency/

Stakeholder Section Comment Response


Senex Production EIR Rev1.2 A1-104

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http://www.petroleum.statedevelopment.sa.gov.au/__data/assets/pdf_file/0018/256230/GAS_Criteria_Tables_for_Borrow_Pits_2014.pdf

http://www.saalnrm.sa.gov.au/BoardDocuments/Plans.aspx



Planning SA (2009). South Australian Heritage Places Database. Accessed in August 2009 at http://www.planning.sa.gov.au/go/Saheritagedatabase. Planning SA, Government of South Australia.

Puckridge J.T., Costelloe, J.F. and Walker, K.F. (1999). DRY/WET: Effects of changed water regime on the fauna of arid zone wetlands (CD-ROM model and documentation). Report to National Wetlands Research & Development Program: Environment Australia and Land and Water Resources Research & Development Corporation, Canberra. ISBN: 0-642-47326-9

Santos (1997). The Arid Zone: Field Environmental Handbook. Santos, Adelaide SA.

Santos (1998a). Environmental Procedure for the Management of Aboriginal Heritage Sites. Santos, Adelaide SA.

Santos (1998b). Code of Environmental Practice Drilling and Workover Operations. Santos, Adelaide SA.

Santos (2003a). South Australian Cooper Basin Joint Venture Environmental Impact Report: Production and Processing Operations, February 2003.

Santos (2003b). South Australian Cooper Basin Joint Venture Environmental Impact Report: Waterflood Pilot Project. Santos, January 2003. Santos Ltd, Adelaide.

Santos (2006). Statement of Environmental Objectives: Geophysical Operations. Prepared for South Australian Cooper Basin Operators, June 2006. Santos Ltd, Adelaide.

Santos (2010). South Australian Cooper Basin Parties Addendum to Environmental Impact Report: Production and Processing Operations. June 2010. Santos Ltd, Adelaide.

Santos (2012a). South Australia Cooper Basin and Arid Regions Geophysical Operations – Environmental Impact Report. February 2014. Santos Ltd, Adelaide.

Santos (2012b). South Australia Cooper Basin and Arid Regions Geophysical Operations - Statement of Environmental Objectives. July 2012. Santos Ltd, Adelaide.

Santos (2014). South Australian Cooper Basin Statement of Environmental Objectives: Production and Processing Operations. February 2014. Santos Ltd, Adelaide.

Santos (2015). South Australia Cooper Basin Statement of Environmental Objectives: Drilling, Completions and Well Operations, November 2015. Santos Ltd, Adelaide.

Santos (2015). South Australia Cooper Basin Environmental Impact Report: Drilling, Completions and Well Operations, November 2015. Santos Ltd, Adelaide.

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9 Abbreviations and Definitions

AAL Associated Activities Licence

AAR Aboriginal Affairs and Reconciliation SA

ADG Code Australian Dangerous Goods Code

ALARP As Low as Reasonably Practical

ANZECC Australian and New Zealand Environment Conservation Council (in reference to the Australian and New Zealand Guidelines for Fresh and Marine Water Quality 2000)

AS 1940 Australian Standard AS1940 Storage and Handling of Combustible Liquids

AS 2885 Australian Standard AS2885 Pipelines – Gas and liquid petroleum

bbls Barrels (1 barrel = 159 litres)

CAMBA China-Australia Migratory Bird Agreement

CAZ PEL182 Controlled Access Zone

CO Carbon monoxide

CO2 Carbon dioxide

DEH Department for Environment and Heritage, South Australia

DEWNR Department of Environment, Water and Natural Resources (formerly DENR/DFW & DEH/DWLBC)

DoEE Department of the Environment and Energy (Commonwealth) (formerly DoE / DSEWPC)

DSD Department of State Development (formerly DMITRE)

EC Electrical Conductivity

EIR Environmental Impact Report prepared in accordance with Section 97 of the Petroleum and Geothermal Energy Act 2000 and Regulation 10

EMS Environmental Management System

EPA Environment Protection Authority (South Australia)

EPBC Act Environment Protection and Biodiversity Conservation Act 1999

ERP Emergency Response Plan

GAB Great Artesian Basin

GAS Goal Attainment Scaling

GRE glass reinforced epoxy

H2S hydrogen sulphide

ha hectare

HAZOP Hazard Operability Process

HDPE High density polyethylene

hydrotest hydrostatic testing

ISO International Standards Organisation

JAMBA Japan-Australia Migratory Bird Agreement

km kilometre

km2

square kilometres

mg/L milligrams per litre

NDT Non-destructive testing



NEPM National Environmental Protection Measure

NGER National Greenhouse and Energy Reporting Act 2007 (Cth)

NPI National Pollutant Inventory

NPWS National Parks and Wildlife Service

PAH Polycyclic Aromatic Hydrocarbon

PEL Petroleum Exploration Licence

PEL Petroleum Exploration Licence

PFW Produced Formation Water

pigging use of pipeline inspection gauges or 'pigs' to perform various maintenance operations on a pipeline, including cleaning and inspecting the pipeline

PIRSA Primary Industries and Resources, South Australia (now DSD)

PPE Personal Protective Equipment

PPL Petroleum Production Licence

psi Pounds per Square Inch

PSV Pressure Safety Valve

ROW Right-of-Way

SACBJV South Australian Cooper Basin Joint Venture

SEB Significant Environmental Benefit

SEO Statement of Environmental Objectives prepared in accordance with the Petroleum and Geothermal Energy Act 2000

Slug catcher the unit in which slugs (a quantity of gas or liquid) at the outlet of pipelines are collected or caught

TPH Total Petroleum Hydrocarbons

waterflood injection of water back into the formation to maintain the pressure in the formation and improve the sweep efficiency, thus improving oil recovery

WIZ PEL182 Walk-in Zone



Appendix 1: Land Systems of North East South Australia



Land Systems of North East South Australia

Land System Land form Description

Blanche Salt lakes Saltlake country often with pale dunes on lake margins. Lake margins of bladder saltbush and samphire; Cobbler Desert with nitrebush, samphire, native myrtle and canegrass.

Bloodwood Dunefields

Gibber

Scattered dunes and sand plains interspersed with gibber gravel flats typical of south eastern Cordillo Downs. Red irregular shaped sand dunes with sandhill spider flower, sandhill wattle and sandhill canegrass; sandplains with bloodwood and lobed spinifex, plains with fine gibber gravel, Mitchell grass, never fail and herbs.

Collina Dunefields

Salt Lakes

Highly eroded and saline dunefield, of truncated parabolic dunes adjacent and north of the Lake Callabonna, Blanche, Gregory complex with predominantly nitre bush dunes with broad saline flats and small plains and many small saline depressions.

Cooper Floodplains

Wetlands

Dunefields

Channels, lakes, swamps and crabhole flats of Cooper Creek floodplain. Main channels with coolibah, river red gum (upstream channels), beantree, river cooba, river emubush, Broughton willow and lignum; swamps with Queensland bluebush, canegrass, old man saltbush, samphire and lignum; lakes lined with coolibah, river couch and rushes; crabhole flats with copperburrs and herbs; pale dunes and sandplains with whitewood / sandhill wattle and sandhill canegrass; red longitudinal dunes with sandhill wattle and sandhill canegrass; interdune flats with variable soils and vegetation.

Diamantina Floodplains

Wetlands

Dunefields

Channels and floodplains of Diamantina River. Land units as for Cooper land system; includes the intricately braided channels of Goyder Lagoon with lignum/ Broughton willow/ Queensland bluebush and canegrass.

Eulpa Dunefields Dunefield in the north east corner of the district on Cordillo Downs. Sand dunes with sandhill canegrass and scattered sandhill wattle; interdune flats with copperburrs, neverfail and annual grasses.

Hope

(formerly Strzelecki)

Dunefields Dune Fields of Strzelecki Desert in the south east of the district. Red dunes with whitewood, mulga, sandhill wattle, sandhill canegrass and lobed spinifex; sandy interdune flats with colony wattle, straggly corkbark over copperburrs and annual grasses; clay swales with Mitchell grass, neverfail and plate grass.

Jeljendi Dunefield Long high dunes of the eastern Simpson Desert with sandhill wattle and waxy wattle over sandhill canegrass and lobed spinifex. Alluvial floodouts with coolibah, Queensland bluebush, lignum and old man saltbush; main channels with coolibah, Broughton willow and river cooba.

Kachumba Floodplains Alluvial outwash plains and channels of Kachumba and Rainbow Plains on Cordillo Downs. Alluvial plains with canegrass, Queensland bluebush and lignum with native millet and copperburrs; creeklines with river red gum

Ketietoonga Dunefields Dune Fields, swamps and lakes of Pandie Pandie, western Cordillo Downs and northern Innamincka. Long red dunes with lobed spinifex, sandhill canegrass and scattered sandhill wattle and narrowleaf hopbush; variable interdune flats with blackbush, starbush and neverfail on clay flats and lobed spinifex on sandy flats; swamps with canegrass and lignum; lakes fringed with samphire and copperburrs on lake beds.

Koonchera Gibber

Dunefields

Gently undulating gibber plains with Mitchell grass, katoora and bladder saltbush. Run on depressions and swamps with Queensland bluebush, cottonbush, canegrass and neverfail; scattered long red sand dunes with sandhill canegrass and desert cynanchum; drainage lines with coolibah, plumbush, river emubush and river cooba.

Lamamour Tablelands

Gibber

Gibber low hills and tableland of Lamamour Plateau on Cordillo Downs. Low hills and undulating plains with barley and curly Mitchell grass, neverfail and common bottlewashers; creeks with river red gum and red mulga; rocky hills and mesas with dead finish and silvertails.

Marqualpie Dunefields

Jumbled dunes, sandplains, channels and swampy flats abutting tableland country on Cordillo Downs and Innamincka. Red dunes with sandhill wattle, sandhill spider flower and rattlepods over dense spinifex; a variety offlats with lignum, canegrass, Queensland bluebush, neverfail, Mitchell grass and coolibah on the channels and deeper depressions; sandplains with mulga;dead finish and bloodwood over woolybutt, spinifex and annual grasses.

Merninie Tableland

Gibber

Gibber tableland and mesas of eastern Innamincka. Tableland and low hills with Mitchell grass, neverfail and copperburrs; mesas with emubushes, gidgee and mulga over bladder saltbush; drainage lines with red mulga, gidgee and river red gum; alluvial plains with Mitchell grass, copperburrs and forbs.



Land System Land form Description

Mulligan Floodplains

Wetlands

Dunefields

Floodplains of Mulligan River which enters South Australia from Queensland on Alton Downs and flows south to Goyder Lagoon on Clifton Hills. Channels with coolibah, Broughton willow, river cooba, beantree and lignum; floodout flats with old man saltbush, cottonbush and Queensland bluebush; red dunes with lobed spinifex, sandhill canegrass, sandhill wattle and sandplain wattle.

Mumpie Tablelands Undulating gibber tableland country. Tableland with gilgais supporting barley and curly Mitchell grass, cottonbush, samphire, bladder saltbush, neverfail and bindyis; mesas with scattered mulga and low bluebush; larger creeks with river red gum, coolibah, Broughton willow and river cooba; minor creeks with dead finish and plumbush.

Simpson Dunefield Active longitudinal dunes running generally north south. Sandhills are dominated by sandhill canegrass with scattered mulga, horse mulga, marpoo, needlebush, hop bush and cassias; dune swales support spinifex with sandhill wattle, sandplain wattle and various shrubs.

Strzelecki Dunefield Dune Fields of Strzelecki Desert in the south east of the district. Red dunes with whitewood, mulga, sandhill wattle, sandhill canegrass and lobed spinifex; sandy interdune flats with colony wattle, straggly corkbark over copperburrs and annual grasses; clay swales with Mitchell grass, neverfail and plate grass.

Sturts Gibber plains

Tablelands

Southern parts of Sturts Stony Desert with gibber downs and scattered red dunes. Lake Howitt and other saline lakes; the mesa jump ups around Mungerannie Gap; undulating gibber plains with gilgais with neverfail, Mitchell grass, cottonbush, scattered lignum and canegrass swamps; sandplains with bladder saltbush, Mitchell grass and katoora; mesas with dead finish, low bluebush, blackbush and shrubby twinleaf; dunes with sandhill wattle over spinifex and sandhill canegrass.

Tingana

(formerly Della or Strzelecki)

Dunefield Dune Fields of Strzelecki Desert in the south east of the district. Red dunes with whitewood, mulga, sandhill wattle, sandhill canegrass and lobed spinifex; sandy interdune flats with colony wattle, straggly corkbark over copperburrs and annual grasses; clay swales with Mitchell grass, neverfail and plate grass.

Tirari Dunefields

Floodplains

Sandhills and flats of the Tirari Desert east of Lake Eyre often known as Peachawarinna country. Includes channels and floodplains of the lower Cooper, Warburton and Kalakoopah Creeks; dunes with sandhill canegrass, desert cynanchum and scattered sandhill wattle; variable flats with starbush, low bluebush and annual grasses; channels with coolibah and scattered nitrebush goosefoot swamps; saltlakes and claypans with samphire.

Warburton Floodplains

Dunefields

Channels, floodplain and associated sand dunes of Warburton Creek. Channels with coolibah, Broughton willow, river cooba and lignum; swamps with Queensland bluebush, old man saltbush and lignum; sand dunes with canegrass, desert cynachium and sandhill wattle.

Wirringina Dunefields

Salt lakes

Red sandplains, dunes and sand accumulations on stony country. Salt lakes including Lake Harry; sand plains and dunes with needlewood, sandhill wattle, sandhill canegrass and starbush; saltlakes with samphire, tangled poverty bush and water weed; kopi lunettes with blackbush, bladder saltbush and Tates bindyi; creeks with coolibah, river cooba and old man saltbush.



Table A2-1: Listed plant species recorded or predicted in the area

Species Common Name AUS SA

Acacia carneorum Needle Wattle V V

Acacia confluens Arkaroola Wattle V

Acacia georginae Georgina Gidgee R

Acacia jennerae Coonavittra Wattle R

Acacia loderi Nealie R

Acacia peuce* Waddy, Waddi, Waddy-wood, Birdsville Wattle V

Acacia pickardii Pickard's Wattle V R

Acacia tenuissima Slender Wattle R

Atriplex eichleri Eichler's Saltbush R

Atriplex kochiana Koch's Saltbush V

Austrostipa pilata Prickly Spear-grass V

Bergia occultipetala V

Brachyscome eriogona R

Bulbostylis turbinata R

Calandrinia stagnensis R

Callitriche sonderi Matted Water Starwort R

Calotis lappulacea Yellow Burr-daisy R

Calotis scapigera Tufted Burr-daisy R

Cyperus bifax Downs Flat-sedge R

Cyperus concinnus R

Cyperus dactylotes V

Cyperus nervulosus R

Elatine gratioloides Waterwort R

Eleocharis plana Flat Spike-rush R

Eragrostis lacunaria Purple Love-grass R

Eremophila gibbifolia Coccid Emubush R

Eremophila polyclada Twiggy Emubush R

Eryngium vesiculosum Prostrate Blue Devil R

Frankenia cinerea R

Frankenia cupularis R

Frankenia plicata Sea Heath E V

Frankenia subteres R

Gilesia biniflora Western Tar-vine R

Goodenia anfracta R

Gratwickia monochaeta R

Maireana pentagona Slender Fissure-plant R

Malacocera gracilis Slender Soft-horns V

Mimulus prostratus Small Monkey-flower R

Neurachne lanigera Woolly Mulga-grass R

Nymphoides crenata Wavy Marshwort R

Ophioglossum polyphyllum Large Adder's-tongue R



Species Common Name AUS SA

Orobanche cernua var. australiana Australian Broomrape R

Osteocarpum acropterum var. deminutum Wingless Bonefruit R

Osteocarpum pentapterum Five-wing Bonefruit E

Phlegmatospermum eremaeum Spreading Cress R

Pimelea penicillaris Sandhill Riceflower R

Podolepis muelleri Button Podolepis V

Ptilotus sp. Cordillo Downs (B.Lay 1487) (NC)

V

Santalum spicatum Sandalwood V

Sauropus ramosissimus V

Sclerolaena blackiana Black's Bindyi R

Sclerolaena fontinalis Mound Spring Bindyi R

Stylidium desertorum V

Swainsona fuscoviridis Dark Green Swainson-pea R

Swainsona leeana Lee's Swainson-pea R

Swainsona microcalyx Wild Violet R

Swainsona minutiflora Small-flower Swainson-pea V

Swainsona oligophylla R

Swainsona procumbens Broughton Pea V

Tecticornia cupuliformis V

Wurmbea deserticola Desert Nancy R

Zygophyllum humillimum Small-fruit Twinleaf R

Zygophyllum hybridum R

1Conservation status under the SA National Parks and Wildlife Act 1972 & Commonwealth Environment Protection and

Biodiversity Conservation Act 1999: R – Rare, V – Vulnerable, E – Endangered, EX – Extinct

* Indicates the species has been predicted to occur by the protected matters search tool (DoEE 2016) but has not been recorded in the BDBSA (DEWNR 2014).

Table A2-2: Listed fauna species recorded or predicted in the area

Species Common Name Conservation Status1

Cth SA

Birds

Actitis hypoleucos Common Sandpiper R

Amytornis barbatus (Bulloo) Grey Grasswren E R

Amytornis modestus Thick-billed Grasswren V

Anas rhynchotis Australasian Shoveler R

Anhinga novaehollandiae Australasian Darter R

Anseranas semipalmata Magpie Goose E

Aphelocephala pectoralis Chestnut-breasted Whiteface R

Aprosmictus erythropterus Red-winged Parrot R

Ardea ibis Cattle Egret R

Ardea intermedia Intermediate Egret R

Ardeotis australis Australian Bustard V




Arenaria interpres Ruddy Turnstone R

Biziura lobata Musk Duck R

Burhinus grallarius Bush Stonecurlew R

Cacatua leadbeateri Major Mitchell's Cockatoo R

Calidris ferruginea Curlew Sandpiper CE

Calidris melanotos Pectoral Sandpiper R

Calidris subminuta Long-toed Stint R

Charadrius mongolus Lesser Sand Plover R

Cladorhynchus leucocephalus Banded Stilt V

Conopophila whitei Grey Honeyeater R

Coturnix ypsilophora Brown Quail V

Egretta garzetta Little Egret R

Elanus scriptus Letter-winged Kite R

Emblema pictum Painted Finch R

Epthianura crocea Yellow Chat E

Falco hypoleucos Grey Falcon R

Falco peregrinus Peregrine Falcon R

Gallinago hardwickii Latham's Snipe R

Geophaps plumifera Spinifex Pigeon R

Grantiella picta Painted Honeyeater R

Grus rubicunda Brolga V

Hamirostra melanosternon Black-breasted Buzzard R

Limosa lapponica bauera* Bar-tailed Godwit (baueri) V ssp

Limosa lapponica menzbieri* Bar-tailed Godwit (menzbieri) CE ssp

Limosa limosa Black-tailed Godwit R

Lophoictinia isura Square-tailed Kite E

Melanodryas cucullata Hooded Robin ssp

Melithreptus gularis laetior Golden-backed Honeyeater R

Myiagra cyanoleuca Satin Flycatcher E

Myiagra inquieta Restless Flycatcher R

Neophema chrysostoma Blue-winged Parrot V

Neophema splendida Scarlet-chested Parrot R

Ninox connivens Barking Owl R

Oriolus sagittatus Olive-backed Oriole ssp

Oxyura australis Blue-billed Duck R

Pedionomus torquatus Plains-wanderer CE E

Pezoporus occidentalis Night Parrot EN E

Phaps histrionica Flock Bronzewing R

Plegadis falcinellus Glossy Ibis R

Pluvialis fulva Pacific Golden Plover R

Podiceps cristatus Great Crested Grebe R

Porzana tabuensis Spotless Crake R

Rostratula australis Australian Painted Snipe E




Stictonetta naevosa Freckled Duck V

Stipiturus ruficeps Rufous-crowned Emuwren R

Tringa glareola Wood Sandpiper R

Tyto longimembris Eastern Grass Owl R

Tyto novaehollandiae Australian Masked Owl E

Mammals

Caloprymnus campestris Desert Rat-kangaroo EX E

Dasycercus cristicauda Crest-tailed Mulgara (Ampurta) V

Dasyuroides byrnei Kowari V V

Leporillus conditor Greater Stick-nest Rat V V

Macrotis lagotis Greater Bilby (Bilby) V V

Macrotis leucura Lesser Bilby EX E

Notomys cervinus Fawn Hopping-mouse V

Notomys fuscus Dusky Hopping-mouse V V

Pseudomys australis Plains mouse, Palyoora V V

Pteropus scapulatus Little Red Flying-fox R

Saccolaimus flaviventris Yellow-bellied Sheath-tailed Bat R

Sminthopsis youngsoni Lesser Hairy-footed Dunnart R

Trichosurus vulpecula Common Brushtail Possum R

Reptiles

Aspidites ramsayi Woma R

Ctenotus astarte Ashy Downs Ctenotus R

Ctenotus joanae Blacksoil Ctenotus R

Demansia rimicola Channel Country Whipsnake R

Emydura macquarii Macquarie Tortoise V

Morelia spilota Carpet Python R

Notoscincus ornatus Desert Glossy Skink R

Proablepharus kinghorni Blacksoil Skink R

Frogs

Cyclorana cultripes Knife-footed Frog R

Uperoleia capitulata Small-headed Toadlet R

Fish

Maccullochella peelii* Murray Cod V

1Conservation status under the SA National Parks and Wildlife Act 1972 & Commonwealth Environment Protection and

Biodiversity Conservation Act 1999: R – Rare, V – Vulnerable, E – Endangered, EX – Extinct 2Subspecies is listed under the National Parks and Wildlife Act 1972, however subspecies information is not contained in

BDBSA records.

* Indicates the species has been predicted to occur by the protected matters search tool (DoEE 2016) but has not been recorded in the BDBSA (DEWNR 2014).



Appendix 3: Summary of 2016 SEO / EIR Revision Changes

Table A3-1: Summary of 2016 SEO Revision Changes*

Key: Additions are in BLUE Deletions are striked-through

Section Description of Change

Section 1, Introduction

Updated to include explanation of the need for a revision

Section 1.2, Scope Updated to describe scope change to include production operations within PEL182.

Section 1, Figure 1 Updated with current Senex fields/tenements

Section 3, Table 1, Objective 1

Assessment Criteria updated to include reference to additional standards e.g. AS, API. Comments column updated to replace use of the term “minimised” with “as low as reasonably practical”.


Change to Objective 3 wording:

2014: Minimise disturbance and avoid contamination to soil.

2016: Minimise disturbance and impacts to soil due to regulated activities or escape

of petroleum, processed substance, chemical or fuel.

Changes to Obj. 3 “Assessment Criteria”:

Construction Activities

No vehicle access in the PEL182 Walk In Zone (WIZ).

Any escape of petroleum, processed substance, chemical or fuel is either immediately contained and removed or assessed in accordance with NEPM guidelines and remediated in accordance with relevant guidelines in a timely manner.

Also refer to Objective 6

Fuel and Chemical Storage, Handling and Transportation

- No serious environmental damage or harm resulting from spills or leaks.

- No spills or leaks that affect an area that has not been specifically designed to contain such an escape.

- Soils remediated in consultation with Department for State Development (DSD) / Environmental Protection Authority (EPA) and to a level determined acceptable by the regulator.

- No impact to soil due to an escape of petroleum, processed substance, chemical or fuel.

Any escape of petroleum, processed substance, chemical or fuel is either immediately contained and removed or assessed in accordance with relevant guidelines in a timely manner.

Oil/Condensate Spills (Pipeline/Road Transport)

- No trucking of oil within the CAZ during periods when water courses are flooded and/or access roads are inundated.

Changes to Obj. 3 “Guide to How Objectives Can Be Achieved”:

- All fuel, oil and chemicals are stored, handled and transported in accordance with appropriate applicable standards and guidelines e.g. AS 1940, EPA requirements Guidelines Bunding and Spill Management 080/12 and Australian Dangerous Goods (ADG) Code.

- Incidents that result in a loss of containment are immediately reported and clean up






actions initiated as soon as practicable.

- Fuel storage with capacity >10,000L contained within double skinned tanks with safety valves.

- Spills or leaks are immediately reported and clean up actions initiated.

- No re-fuelling occurs outside designated refuelling areas.


- Implement appropriate flood and road condition monitoring and reporting procedures

- Pipelines are compliant with AS2885 pipeline standards and the relevant Pipeline Integrity Management Plan.

Changes to Obj. 3 “Comments”:

Subsurface access for drilling/production activities are permitted within the WIZ, but surface access for petroleum activities within the WIZ is limited to foot based geophysical activities only (i.e. no surface vehicle access can occur within the WIZ).

Localised contamination impacts may result from spills or leaks of well operation chemicals during storage and handling.




- No vehicle access in the PEL182 Walk In Zone (WIZ).

Borrow Pits

0, +1 or +2 GAS criteria for goals related to this objective as listed in (Appendix A, Table A1 to A2) or where 0, +1 or +2 GAS criteria implemented in a timely manner. (Note: see Objective 13 for final borrow pit rehabilitation (i.e. at relinquishment)) are not attained; plans for remediation are documented and construction. implemented in a timely manner. (Note: see Objective 13 for final borrow pit rehabilitation (i.e. at relinquishment)).


Undertake a review of legacy borrow pits established prior to the introduction of the 2014 GAS criteria (DSD, 2014) using a risk based approach to identify pits that are a priority for management.


Subsurface access for drilling/production activities are permitted within the WIZ, but surface access for petroleum activities within the WIZ is limited to foot based geophysical activities only (i.e. no surface vehicle access can occur within the WIZ).



- Discharge water (e.g. vehicle and equipment wash-down water) appropriately collected and disposed of in accordance with ANZECC and EPA criteria.




- No new water affecting activities as defined under the NRM Act undertaken unless relevant permits have been obtained.

- No unauthorised discharge of water (or other liquid) or solid wastes to surface waters.

- No impacts to groundwater or surface water contamination as a result of construction






activities.

- No blockage of any creek1 channels within the PEL182 CAZ.

- No earthmoving activities to occur within the PEL182 CAZ when floodwaters2 pose

an inundation risk to areas where earthworks are occurring or proposed to occur.

1Creeks are defined as those minor and major watercourses mapped to occur within the

CAZ by the DEWNR topographical watercourse mapping dataset (DEWNR, 2016).

2 Floodwaters are defined as an overflow of a large amount of water beyond the normal

limits of a watercourse.

Production Activities

- No unauthorised discharge of water (or other liquids) to groundwater or surface water contamination.

- Any escape of petroleum, processed substance, chemical or fuel is either immediately contained and removed or assessed in accordance with NEPM guidelines and remediated in accordance with relevant guidelines in a timely manner.

- All creek1

crossings of pipelines within the PEL182 Controlled Access Zone (CAZ) are to be buried and incorporate:

two physical mechanisms of oil spill protection2; and

two systematic mechanisms of oil spill protection2.



2As defined by measures outlined in AS2885 Pipelines-Gas and liquid petroleum Part 1:

Design and construction Section 5.5.4.

Fuel and Chemical Storage, Handling and Transportation

No water (surface or impacts to groundwater) contamination or surface water as a result of these activities.


- All creek1

crossings of pipelines within the PEL182 Controlled Access Zone (CAZ) are to be buried and incorporate:

two physical mechanisms of oil spill protection2; and

two systematic mechanisms of oil spill protection2.



2As defined by measures outlined in AS2885 Pipelines-Gas and liquid petroleum Part 1:

Design and construction Section 5.5.4.



- Fuel, oil and chemicals are stored, handled and transported in accordance with applicable standards and guidelines e.g. Australian Standard AS 1940, Australian Dangerous Goods (ADG) Code, EPA guidelines 080/12 Bunding and Spill Management.

- Implement appropriate flood monitoring and reporting procedures

Production Activities

- Creek1 crossings of pipelines in the CAZ, will be constructed in accordance with the






control measures specified for sensitive areas under AS2885 Pipelines - Gas and Liquid Petroleum Part 1: Design and Construction Section 5.5.4 Design for Protection.

Production facilities constructed to avoid spread of hydrocarbons during inundation following localised rainfall (e.g. appropriately sized/elevated bunds in accordance with the EPA Liquid Storage - Bunding and Spill Management Guidelines 080/12 (2012).

Oil/Condensate Spills

- Pipelines have additional protection measures in watercourses areas, in accordance with AS2885 pipeline standards.

- Creek1 crossings of pipelines in the CAZ, will be constructed in accordance with the

control measures specified for sensitive areas under AS2885 Pipelines - Gas and Liquid Petroleum Part 1: Design and Construction Section 5.5.4 Design for Protection.



- No change in the capacity of third-party groundwater users to undertake their respective activities.

- No unauthorised discharge or escape of any liquids (including water, petroleum, processed substance, chemical or fuel), or solid wastes to groundwater.

- No impact on groundwater dependant ecosystems as a result of groundwater extraction or contamination

1 (i.e. aquifers that may provide base flow to nearby

waterholes).

Footnotes:

1Definition of contamination – as per section 5B of the Environment Protection Act 1993


- Monitoring programs implemented (e.g. through well logs, pressure measurements, casing integrity measurements and corrosion monitoring programs) to assess condition of barriers

- Where integrity monitoring identifies potential issues, a risk assessment to evaluate safety and environmental impacts is undertaken to develop prevention and mitigation controls where appropriate.

- Compliance with the current Environment Protection (Water Quality) Policy 2015.


Note: The Cooper Basin Drilling, Completions and Well Operations SEO specifies detailed requirements for aquifer protection.

Note: The Drilling and Well Operations SEO specifies detailed requirements for aquifer protection.



Sewage and Grey Water

- All wastewater (sewage) disposal is in accordance with the South Australian Public Health (Wastewater) Regulations 2013 (which requires that the waste water disposal

system must either comply with the SA Health On-site Wastewater Systems Code or be operated to the satisfaction of the Department of Health) and the Environment Protection (Water Quality) Policy 20032015.








Borrow Pit Restoration

The attainment of 0, +1 or +2 GAS criteria for final borrow pit ‘Rehabilitation’ (i.e. at relinquishment) as listed in Appendix Table A3 unless alternative agreement is reached with the regulator and stakeholders.


Construction Site and Access Track Restoration

- Where possible and subject to operational schedules, progressive rehabilitation of disturbed sites will be undertaken.

- Redundant plant and equipment, and associated infrastructure, is considered for reuse, recycling or disposal in accordance with applicable regulations.

- Areas where plant and equipment have been decommissioned and removed, the site will be reinstated and rehabilitated.

In assessing, and subsequently mitigating, the potential for impact and the success of rehabilitation activities, consideration will be given to the GAS criteria. A GAS criteria outcome of -2 or -1 will trigger the requirement to undertake an assessment to qualify what is the potential long-term and/or post activity impacts to sensitive environmental receptors. Where the assessment identifies that the long-term health of sensitive environmental receptors and/or post activity use of land may be compromised remedial works will be undertaken to meet the Expected GAS Goal (0).


Construction, operation and decommissioning activities that result in disturbance to land and/or drainage channels, or contamination of soils, surface waters or groundwater, either by their nature (e.g. authorised land clearance) or through abnormal or emergency events (e.g. loss of containment) will be rehabilitated (if required) to ensure that activities associated with the identified end land use will not be negatively impacted.

Section 4, Reporting Minor changes to wording and formatting

List of Abbreviations Updated

References Updated

Appendix A, Tables A1-A3

Updated to include the following note on Borrow Pits:

Note: Borrow pits established prior to the introduction of the November 2014 GAS criteria (DSD, 2014) and are suspended (i.e. not yet rehabilitated) may not achieve a 0, +1 or +2 score under the 2014 GAS criteria until immediately prior to license relinquishment. This should not be considered a non-compliance in the interim. Senex is proposing to undertake a review of existing borrow pits using a risk-based approach to identify borrow pits that are a priority for management.

DSD 2014 Borrow Pit GAS Criteria tables A1 to A3 added to Appendix A.

Appendix A, Table A4

Note added to apply to Objective: The revegetation of indigenous species, cross-referencing Goals: Less than five years since abandonment* and At least five years since abandonment*

* Note: Assessment will take into account that revegetation is a time and rainfall dependent process.

*Excludes formatting changes and inconsequential minor edits.



Table A3-2: Summary of 2016 EIR Revision Changes*



Section 1, Introduction and Background

Updated to include explanation of need for a revision

Section 1.1.1, PEL182 Coongie Lakes SMZs

Updated with description of PEL182 Coongie Lakes Special Management Zones and gazettal conditions.

Section 1.3, About this Document

Updated to include reference to additional EIRs

Section 1.3.1, Scope Updated to include scope increase to address operations with PEL182 and Controlled Access Zone.

Section 1.3.1 Figures 1 to 2 added and Figure 3 updated to reflect current Senex production operations

Section 2.2, Other Legislation

Reference legislation updated to include the Dangerous Substances Act 1979 – in relation to the keeping, handling, transporting, conveyance, use and disposal, and the quality, of dangerous substances; and

Section 2.2, EPBC Act / EPBC Act and PEL182

Section updated to address production operations in PEL182 in relation to compliance with the EPBC Act 1999.

Section 3.1, Production Facilities

Table 3 updated with current Senex production facilities and infrastructure.

Section 3.2.1, Water Treatment and Disposal

Updated to include more detail on third guard/holding pond:

Free form evaporation systems require at least two specially constructed and bunded interceptor ponds prior to discharge into a holding pond. Following a suitable residency time in the bunded holding pond (third pond, typically lined with clay or an impervious liner) the PFW is released into the freeform pond. The holding pond acts as a safety mechanism in the event of a hydrocarbon release to the system. Residence times within the water treatment system and ponds are designed to allow for the effective removal of hydrocarbons and ensure the discharged PFW has a hydrocarbon content of less than 10mg/L.

Figures 5 and 6 updated to include third guard/holding pond in diagrams.

Section 3.5, Road Construction and Maintenance – Borrow Pits

Site selection, environmental management and restoration of borrow pits is undertaken in accordance with the SEO (Senex procedures, 2016) and guidelines contained in the SEO. DSD GAS Criteria for the construction, management and rehabilitation of borrow pits (DSD, 2014). Existing borrow pits are used in preference to new ones where appropriate.

Footnotes:

DSA are undertaking a study which is expected to generate new borrow pit criteria. In the interim, the criteria in the accompanying Senex Energy Production Operations SEO and the Drilling and Well Operations SEO (Santos 2009) will be used. These include a minimum distance of borrow pits from non-public access roads of 10 m (Senex SEO) and a minimum distance from public roads of 50 m (Drilling and Well Operations SEO). 1 Note: Borrow pits established prior to the introduction of the November 2014 GAS

criteria (DSD, 2014) and are suspended (i.e. not yet rehabilitated) may not achieve a 0, +1 or +2 score under the 2014 GAS criteria until immediately prior to license relinquishment. This should not be considered a non-compliance in the interim. Senex is seeking to undertake a review of existing borrow pits using a risk-based approach to identify borrow pits that are a priority for management.

Section 3.7, Oil Updated to reference: EPA ‘Liquid Storage - Bunding and Spill Management Guidelines






Transport Version 080/12’ (2012).

Section 3.8.3, Contaminated Soil Treatment / Soil Remediation Areas

A suitable spill remediation method will be selected based on volume, estimated horizontal and vertical impact and the environmental sensitivity of the impacted environment. Minor spills in lined bunded areas are generally treated in situ in accordance with EPA guidelines. The main method of treatment and disposal of hydrocarbon contaminated soil outside of bunded areas is through insitu treatment or removal to a Senex production facility for temporary storage in a designated bunded area. The Contaminated soil that is then unable to be remediated onsite will be transported by a licensed regulated waste contractor to a suitable EPA licensed landfill for treatment or disposal.

Section 4, Existing Environment

Introductory text updated to reflect input of information contained in previous EIRs on PEL182.

Section 4.1, PEL182 Existing Environment Additional sections added to describe PEL182 existing environment.

Section 4.3.1, PEL182 Landforms, Land systems and Soils

Additional section added to describe PEL182 Landforms, Landsystems and Soils

Section 4, Table 8 Updated to include recent Senex production facility and infrastructure changes.

Section 4.4, Flora and Fauna

Updated to include more detail on Flora and Fauna that occur within the PEL182 region.

Section 4.4.3, Threatened Species and Communities

Updated to include more detail on threatened species that occur within the PEL182 region.

Section 4.4.4, Coongie Lakes Ramsar Wetland and EPBC Act

Additional section added to address the Coongie Ramsar Wetland and the EPBC Act.

Section 4.4.5, Introduced Pest Plants and Animals

Updated to include pests and plants of PEL182 region.

Section 4.5, Surface Water Updated to include more detail on PEL182/CAZ surface water hydrology.

Section 4.8.1, Aboriginal Cultural Heritage

Updated to include further detail on the cultural heritage assessment process for undertaking regulated activities.

Section 5.1, Overview of Risk Assessment Process

Tables 12, 13 and 14 updated to reflect current Senex consequence and likelihood definitions, and risk assessment matrix (updated in 2016).

Section 5, Environmental Risk Assessment

All production activity risk assessment tables (Tables 16 to 26) updated in accordance with current Senex consequence and likelihood definitions, and risk assessment matrix (updated in 2016).

Section 5.2.2, Facility Operation

Updated to include reference to EPA ‘Liquid Storage - Bunding and Spill Management Guidelines’ 080/12’ (2012).

And the following text;

This includes, but is not limited to, fuels and chemicals being stored with appropriate secondary containment such as double skinned tanks (fuel storage), appropriate bunding capacity for chemicals and flammable liquids in accordance with EPA






requirements, and the undercover storage of chemicals where practicable.

Section 5.2, Production Facility, Table 16: Production Facility Risk Assessment

Table 16 updated with the following additions:

Activity/Event: Earthworks associated with facility construction (e.g. clearing, grading)

Changes to “Potential Consequences”


Changes to “Management Strategy”





No blockage of any creek1 channels within the PEL182 Controlled Access Zone (CAZ).


Activity/Event: Loss of containment of oil outside area designed to contain spills (pipe rupture or leaks from plant equipment)


Creek1 crossings of pipelines in the PEL182 Controlled Access Zone (CAZ) shall

include two physical mechanisms 2 and two systematic mechanisms

of oil spill

protection.

Footnotes: 1Creeks are defined as those minor and major watercourses mapped to occur within

the CAZ by the DEWNR topographical watercourse mapping dataset (DEWNR, 2016). 2As defined by measures outlined in AS2885 Pipelines-Gas and liquid petroleum Part

1: Design and construction Section 5.5.4.

Section 5.4, Waterflood, Table 18: Waterflood risk assessment

Table 18 risk ratings updated in accordance with Senex 2016 consequence and likelihood definitions, and risk assessment matrix.

Section 5.5.2, Pipeline Operation, Table 20: Pipeline construction risk assessment

Table 20 updated with the following changes:

Activity/Event: Earthworks associated with facility construction (e.g. clearing, grading)





Restore borrow pits


Borrow pits re-used as evaporation or water storage ponds where appropriate









the CAZ by the DEWNR topographical watercourse mapping dataset (DEWNR, 2016).

Activity/Event: Movement of heavy machinery and vehicles along construction easement and access tracks


Activity/Event: Spills or leaks associated with chemical and fuel storage and handling No trucking of oil within the CAZ during periods when water courses are flooded and/or access roads are inundated.

Section 5.5.2, Pipeline Operation, Table 21: Pipeline operation risk assessment

Table 21 risk ratings updated in accordance with Senex 2016 consequence; and Table 21 updated with the following changes:

Activity/Event: Spill or leak associated with pipeline failure to land



include two physical mechanisms2 and two systematic mechanisms

2 of oil spill

protection.

Activity/Event: Spill associated with pipeline failure in a watercourse



include two physical mechanisms2 and two systematic mechanisms

2 of oil spill

protection.


the CAZ by the DEWNR topographical watercourse mapping dataset (DEWNR, 2016). 2

As defined by measures outlined in AS2885 Pipelines-Gas and liquid petroleum Part 1: Design and construction Section 5.5.4.

Section 5.6, Road Construction and Maintenance, Table 22 Road Construction and Maintenance risk assessment Road Construction and Maintenance Road Construction and Maintenance

Table 22 updated with the following changes:

Activity/Event: Earthworks and physical presence of road







No earthmoving activities to occur within the PEL182 CAZ when floodwaters pose an inundation risk.

Activity/Event: Movement of heavy machinery and vehicles along road and access tracks


No earthmoving activities to occur within the PEL182 CAZ when floodwaters pose an






inundation risk of the area where earthworks are occurring or proposed to occur.

Activity/Event: Spills or leaks associated with chemical and fuel storage and handling


Activity/Event: Presence of borrow pits



Borrow pits are restored to a standard consistent with the surrounding land use, to achieve a +2, +1 or 0 Goal Attainment Scaling score (refer to SEO)

Note: DSD are carrying out a study which is expected to generate new criteria for borrow pit establishment and restoration. In the interim, the criteria in the accompanying Senex Energy Production Operations SEO and the Drilling and Well Operations SEO (Santos 2009) will be used.

Activity/Event: Movement of road construction material



Activity/Event: Use of roads



Section 5.8, Oil Transport (By Road), Table 24: Oil transport risk assessment

Activity/Event: Spill associated with transport of oil / condensate (via truck) to land



Section 5.10, Decommissioning / Rehabilitation, Table 26: Decommissioning / rehabilitation risk assessment

Activity/Event: Movement of machinery and vehicles along ROW and access tracks during rehabilitation



Section 6.6, Environmental Procedures

Reference to Senex Cultural Heritage and Native Title Management Procedure (Senex 2016) added.

References Updated

List of Abbreviations Updated


Updated to reflect changes in species conservation ratings for region (including PEL182).



*Excludes formatting changes and inconsequential minor edits.