Mining open slather on underground water continues

by George Houen, Landholder Services Pty Ltd

Image sourced [here] 

 

 

 

 

 

 

Miners will get to keep the Newman government’s gift of open slather on groundwater, plus the waiving of both the water licence requirement and the obligation to justify the volume of water they extract - and they will be able to use or dispose of the water any way they wish including by evaporation, which for obvious environmental reasons was banned in coal seam gas fields years ago.

At least miners who dewater will, for the first time, be subject to Chapter 3 of the Water Act which imposes a make good obligation and requires underground water impact reports. Successive governments have assured bore owners that if there is bore damage from dewatering the Chapter 3 make good scheme will protect them – that is false and when the scheme is called upon for a contested make good scheme the affected owners will find it is tragically flawed.

Natural Resources and Mines Minister Anthony Lynham announced on 10th November which parts of the previous governments water amendments he intends to repeal or amend. But open slather for miners stays – and after consultation with the Environment Minister and with stakeholders as to how it will operate it will be proclaimed into force, including for existing mines, on a date to be agreed.

Provided a mining lease and an environmental authority have been granted, unlimited dewatering is OK, even in a worst-case situation where dewatering is virtually certain to damage or destroy water bores as well as groundwater dependent flora or fauna.

Under present laws, groundwater impacts are a major factor in any environmental impact assessment for mining - often giving rise to objections supported by high-level expert evidence in the Land Court’s objections hearings. The Court directs any resulting recommendations on groundwater to the Environment Minister for consideration in deciding the environmental authority application.

But the Court under present laws doesn’t have jurisdiction to make recommendations about the licence for dewatering which - until proclamation of the change - is under the separate jurisdiction of Natural Resources and Mines. This segregation is artificial and should have been removed. However, under the Water Act an interested person who disputes grant of a water licence can request internal review of the decision and can also appeal to the Land Court about it.

Allowing dewatering without a water licence doesn’t alter the Environmental Protection Act assessment process for the proposed mine, nor does it alter the Land Court’s role as the independent assessor which makes recommendations to the Minister. Both of those phases are designed to assess and test the evidence on overall environmental impact (including impacts on groundwater and water users) and applications for environmental authority.

In spite of the miners gaining open slather dewatering, the current process of overall environmental assessment including the impacts on groundwater resources and on users of water bores, with a right for the public to object and be heard in the Land Court, will continue.

This tussle over the Newman government’s amendments gave Minister Lynham a golden opportunity to remove artificial demarcation and integrate the approval of dewatering with the well-established environmental assessment system – he let it slip. Now I expect that, true to form, mining company lawyers will use the advent of open slather dewatering and abolition of the requirement for water licenses to argue that objections about groundwater be no longer permitted.

RELATED PREVIOUS PUBLISHED ARTICLES

The Newman Government’s Water Act amendments: Part 1 - Deregulation of the Dewatering of Mines 

The Newman Government’s Water Act amendments: Part 2 - Uncoordinated Approval System 

The Newman Government’s Water Act amendments: Part 3, Make Good 

The Newman Government’s Water Act amendments: Part 4 - Stream diversions

Dewatering Mt Gibson Iron Ore mine, photo sourced [here]

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Newman Government’s Water Act amendments: Part 4 - Stream diversions

by George Houen

McArthur River Mine, photo sourced [here] 

Stream Diversions 

Setting the miners free to dewater as much as they like and without any prior impact assessment is  not consistent with the Bill’s treatment of miners’ authority to divert surface water in streams, which currently also requires a water licence. Under the amended section 98 of the Water Act they may only divert a stream if the particular diversion and its impacts were assessed as part of the grant of an environmental authority and a condition of the authority allows it.  

Comment 

It should be permissible that objections against an environmental authority or its conditions (including any Coordinator General’s conditions) may include objections against a proposed stream diversion.

 

First Refusal for Affected Landholders 

Under the Bill’s clause 334Z of the MR Act, the miner may use the associated water for any purpose anywhere. This could result, for example, in groundwater which the bore owner is entitled to and is relying upon, being taken and used by the miner off lease for a non-mining purpose, or sold to someone else for a non-mining purpose.  

Comment 

Where the dewatering produces associated water in excess of a miner’s requirements for the mining purposes, the miner should be required to treat the surplus by reverse osmosis, then give all potentially affected landholders first right of refusal to take the treated water for their own use, at no cost.

 

Agreement 

A template make good agreement (which is readily adapted for either mining or CSG) is available from landholder Services. It was first adopted at the Callide Mine some 6 years ago and has been subjected to extensive review since. Provisions for baseline testing, monitoring and setting of trigger levels in the original agreement have operated satisfactorily. 

 George Houen

Landholder Services Pty Ltd

13 Cottesloe Street

Toowoomba

Qld 4350

Phone 07 4632 1024

 

 

 

Previous published related posts

The Newman Government’s Water Act amendments: Part 1 - Deregulation of the Dewatering of Mines

The Newman Government’s Water Act amendments: Part 2 - Uncoordinated Approval System

 

The Newman Government’s Water Act amendments: Part 3, Make Good

 

The Newman Government’s Water Act amendments: Part 3, Make Good

Photo sourced: Farmer claims mine water monitoring is flawed

By George Houen

Make Good

Mine dewatering is to be subject to the Water Act provisions requiring underground water impact reports, baseline assessments, general agreements and make good agreements. These will do little if anything to protect the rights of other groundwater users.

 

 

Miners will hide behind the one-side and trivial provisions of the Water Act to frustrate any attempts by landowners to achieve make good agreements that are actually workable and enforceable. The limited  bargaining power which the landowner may have during the current objection process will no longer count for anything as far as a make good agreement is concerned.  

The Water Act make good provisions are so one-sided and fundamentally flawed that in practical terms are they unenforceable, for example:

1. settlement of a make good agreement is not required before dewatering begins, so the landholder has no bargaining power – only a recourse to the Court and the Court would be restricted by these badly designed Water Act provisions
2. no requirement for independent expert testing of bores;
3. bore owner not entitled to the data and reports
4. baseline testing of private bores inadequate (especially as sustainable yield and gas intrusion not tested)
5. no regular monitoring of private bores including for specific capacity (short-form yield test) and gas intrusion
6. no expert-determined declining value trigger levels for individual bores derived from monitoring data (just one-size-fits-all water level decline which is not conclusive proof of diminished capacity)
7. no process for independent expert interpretation of impaired capacity and its cause when trigger levels reached
8. no process for resolving appropriate make good action
9. no dispute resolution process for technical matters requiring expert assessment
10. both make good and compensation are assessed according to the ‘authorised purpose or use’ of the bore, ie. its licensed yield limit (if there is one) and description of its utilisation at the time of baseline testing. Either or both of those parameters may be substantially below the bore’s actual capacity.

Comment

Licenced yield (if the bore is subject to licensing) can be amended. Subject to that upper limit it is the owner’s right to use the bore’s full capacity and it is that full capacity which must be underwritten by the make good system.  

The Water Act make good scheme fails to test (baseline test) and track (by monitoring) an individual bore’s actual capacity and thereby accurately identify any adverse change and its cause. Data from those in-house assessments isn’t required to be shared with the bore owner. Those

broad groundwater assessments and reports under the Water Act will gather a vast bank of data which is of little if any use when it comes to achieving a just outcome for the owner of a damaged bore.

 

More detail of the dysfunctional nature of the make good scheme may be found in ‘Make Good Flaws’, a supplementary document from Basin Sustainability Alliance at the 29thOctober 2014 public hearing of the Agriculture, Resources and Environmental Committee of Parliament.   

As is painfully obvious from experience in make good negotiations with CSG companies, such weak and inadequate terms in the Act are used by resource companies as a shield to deflect and frustrate any attempt by landholders to negotiate realistic and enforceable terms of a make good agreement. 

As stated above, dewatering approval should only granted after the proponent has entered into a make good agreement with each potentially affected bore owner.

 

Private make good agreements can meet all the tests referred to above. In both parties’ interests the agreement must lay out a process for gathering and supplying to both parties the necessary up to date data and fact and independent expert assessment. Both parties require that information as evidence in the event a make good claim arises. The resource company’s right to challenge a make good claim in court must be respected. The onus of proof of damage and its cause is on the bore owner and the standard of proof is demanding, so that the agreement must ensure the necessary data and fact are available if needed.

 A government-sponsored standard make good agreement would be appropriate, but that should be the extent of the Government’s involvement.

Areas in Surat Basin where aquifers will be impacted by coal seam gas
Prepared by the Office of Groundwater Impact Assessment
Managing groundwater impacts of coal seam gas

 

 Previous published related posts

The Newman Government’s Water Act amendments: Part 1 - Deregulation of the Dewatering of Mines

The Newman Government’s Water Act amendments: Part 2 - Uncoordinated Approval System

The Newman Government’s Water Act amendments: Part 2 - Uncoordinated Approval System

 by George Houen

Image sourced Qld Government, water bores

Uncoordinated Approval System
 

Currently mine dewatering must be authorised by a water licence under the Water Act, application for which is a separate process from the mining lease and environmental authority and it occurs separately and much later. It also has its own appeal process, for which the Land Court is also the arbitrator. 
 

The Land Court has found that currently it has only marginal jurisdiction on the issue because the water licence is not part of an objections hearing. This leaves landholders potentially affected by impacts of dewatering with nowhere to go. President of the Court CAC MacDonald, in her judgement on the objections hearing for the Wandoan Coal project², addressed her observations about this undesirable dichotomy to the respective Ministers for Mines and Environment, saying (inter alia) at [608]: 
 

             … The impacts of water diversions and extractions associated with the project seem to me to be highly relevant to any consideration of whether the project should be approved or refused. In my opinion, it is unsatisfactory that the impacts of water extractions and diversions are not properly assessed and considered under the Water Act until after the project has been approved under the MRA and the EPA.

 

The separate (and later) water licence application and approval process doesn’t allow cumulative impacts of mining to be properly addressed and by the time a decision is made on grant of a water licence it is likely that the mining project will already have been approved. Thus it is unlikely the decision maker for the water licence will reject the application and so derail the project. If a landholder did appeal the grant that would be a doubling up of their cost and time spent on an objections hearing.                     

Some water licenses for mine dewatering may have make good conditions, but never on terms that realistically are enforceable – ie. no proper baseline testing of the individual bore for sustainable yield (water levels are not enough), no proper monitoring to develop data and no properly derived trigger values. That is, a bore owner relying on such a make good condition could not meet the onus of proof or the standard of proof required to sustain a make good claim.   

 

Comment

The present legislation governing approval of mine dewatering is dysfunctional and needs to be fixed – not by the process set out in the Bill but by way of a scheme:

1. placing approval of mine dewatering under the Environmental Protection Act;
2. integrating objections with the mining lease/environmental authority approval process, such that cumulative impacts cab be assessed;
3. providing transparency, appropriate assessment of impacts and the right for objectors to be heard before the Land Court;
4. making dewatering conditional upon the proponent having first settled make good agreements with all potentially affected bore owners;
5. putting disposal of associated water from mines on a similar footing to the disposal obligations of CSG producers, ie. requiring it only be released after treatment by reverse osmosis;
6. the miner’s right to use the associated water for any purpose anywhere be subject to first offering it free of charge to landholders affected by the dewatering.

 

It seems inappropriate that this authority to dewater (including by evaporation from a mine pit) is placed in the Mineral Resources Act. Perhaps this is done deliberately to exploit the prohibitions and limitations placed on mining lease objections by the Common Provisions Act. 

 

 

 

Image sourced ABC: Coal Seam Gas by the numbers.



Previous published related post

The Newman Government’s Water Act amendments: Part 1 - Deregulation of the Dewatering of Mines 

The Newman Government’s Water Act amendments: Part 1 - Deregulation of the Dewatering of Mines

by George Houen

 

Deregulation of  the Dewatering of Mines

To clear the way for the extraction process in open cut and longwall underground coal mining (and to a lesser extent other minerals), miners pump accumulated groundwater out of the pit, they also pump from bores to dewater the ground in advance. 

Image sourced [here]

 

 

 

The pit becomes a sump which drains all aquifers overlying the target coal seam, and the coal seam itself. The resulting drawdown extends outward in a radius determined by permeability of the ground and interconnection between aquifers. One expert report for the Galilee Basin predicted the radius of permanent drawdown to extend 30km – even with lesser distances, the scope for damage  to landholder’s bores is obvious.

 

 

 

 

 

That this dewatering has major implications for the environment and for owners of water bores is authoritatively shown by Land Court’s Alpha Coal judgement¹, in which the primary recommendation was to reject the mining application. Despite extensive expert study and evidence on groundwater, the Court found that evidence unsatisfactory as to the impact of the mine’s dewatering on other groundwater users and on the ecology. The Court’s fallback recommendation made any approval for the mine conditional upon:

1.  the proponent first obtaining water licenses on conditions which resolve all concerns pursuant to the precautionary principle, and
2. additional groundwater monitoring points on each of the objectors’ properties, and
3. the proponent must enter into make good agreements with each of the three objectors either within 12 months of grant of the mining lease, or before mining activities commence, whichever is the sooner.   

In contrast to the impacts of mine dewatering, dewatering for CSG (which is unregulated) targets the specific gas-yielding coal seam. It is usually deeper than the water supply aquifers and usually with poorer quality water. It is dewatered to liberate the gas from fissures in the coal. Except where private bores actually draw from that same seam, the impact of CSG dewatering on water bores is indirect. In response to the alteration in relative water pressures, and depending on permeability and interconnections, water from other aquifers may flow to the dewatered coal seam. Because the coal itself is not disturbed, presumably it is possible in the long term that the original saturation and pressure balance would be reinstated. 

Comment

The Land Court’s Alpha Coal decision shows, as is common sense, that mine dewatering impacts are difficult to predict but involve major, direct and permanent impacts on the groundwater relied upon by landholders and townsfolk, as well as significant environmental impacts. Accordingly mine dewatering should be made an integral part of the approvals process. But as explained below, CSG dewatering is very different in its process and its impacts. The proposition that mine dewatering needs to be deregulated to put miners on an even footing with CSG operators is contrived and invalid.

Skid mounted pump installed on a barge in a coal mining operation
Photo sourced [here]

 

Previous Related Posts

The Newman Government’s Mining Reforms - Part 1 Common Provisions, Restricted Land

 

The Newman Government’s Mining Reforms - Part 2 Common Provisions, Mining lease application and notification

 

The Newman Government’s Mining Reforms - Part 3 Common Provisions, Objections

 



Disappointing; water drillers smeared with CSG asbestos drilling mud

 

by Ian Hansen

 

With regard to the asbestos being found in drilling mud, I find it very disappointing and irresponsible that Mayor Ray Brown finds a need to place the water drilling industry under the same umbrella as the CSG drilling industry with his statement "the same mud is used in many water bore drills".

The drilling mud additive in question is ‘nutplug’ consisting of mainly ground walnut shells used in the drilling process to stop lost circulation.  This is where the mud is lost to porous formations.  Whereas this product and others similar are freely available to all in the drilling industry it is not favoured by most water drillers as they tend to block the aquifers and make it difficult to develop a bore to its full potential. 

Mayor Ray Brown Western Downs Regional Council outside a gas fired power station in his electorate. Photo sourced AFR

I have been drilling water bores within the artesian basin of Queensland for more than 36 years and have never had the need to use these products in any of the formations within the GAB.

Also with current restrictions on town water supplies after major flooding in the recent past, and a moratorium stopping towns people drilling bores to supply their own water, people are becoming increasing frustrated watching millions of litres of precious ground water from CSG production being wasted in evaporation ponds. 

This is after the original big sales pitch by the CSG industry that there would be abundant water for industry, urban and some agriculture needs.

With Origin applying for 100m/l of allocation per year from the Huttons to supply their power station and Miles being granted 800m/l per year from the Precipice sandstone, would it not be more beneficial to first utilize the CSG water rather than placing only more pressure on our ground water supplies?

Could Mr Brown as Mayor of the Western Downs and also a Gas Fields Commissioner, please explain why CSG water isn’t being used. Is it because of CSG companies demanding cheaper options; is it because the quality of the water can’t be guaranteed or is it because consistent volumes can’t be supplied?

Why is it necessary for the CSG drilling industry to use lost circulation products, such as "nutplug", when water drillers have been able to construct water bores in these same formations without it.

 I find it very disappointing that Mayor Ray Brown sees the need to try to involve the water drilling industry into this issue

Previous article by Ian Hansen

CSG: Open mineral exploration holes

 

Watch for the 1,999 hectare footprints

The big four coal seam gas companies in Queensland have had their major projects approved. By the evidence presented firstly by the Courier Mail newspaper and secondly by ABC TV Four Corners program the approval process left much to be desired. To learn more of these events read an earlier post on this site, Gas leak response. Recently the Crime and Misconduct Commission (CMC) cleared any wrongdoing in the approval process mostly by a neat side step of that matters raised '… do not fall within the CMC’s jurisdiction.’  For further reading go to this highly referenced and detailed report of what has occurred in the online Independent Australian article, How the Queensland Government fracked the State

Despite its many flaws the big projects to this point were subjected to an approval process. They had to negotiate an Environmental authority (EA) with the government. They hired consultants to prepare mind blowing large Environmental Impact Statements (EIS) which were open to a public review and submission process. EIS look at more than just environmental impacts; they also include impacts on the likes of cultural heritage, transport, agricultural production and the very important underground water impacts. Each coal seam gas company are developing tenements they hold outside the areas approved within their current projects and to bring each of these new areas into production one would have thought that they would need to be scrutinised for any major impacts on conservation values or top farming soils etc.; but apparently not.

Take the example of the British Gas owned QGC project, Queensland Curtis Liquid Natural Gas (QCLNG) project which was approved for mapped area that included 6,000 gas wells, CSG water storage ponds, linking roadways, linking gas & water pipes, compressor stations, processing plants, accommodation camps, export gas pipeline and a LNG plant on Curtis Island.

The first photo (above) was taken at the end of November 2013 shows the QGC Woleebee Creek processing plant under construction; a massive piece of industrialisation lifting out what was once quiet cattle paddocks west of Wandoan in what was once amongst Australia’s best beef fattening country.

On the 6^th November the Australian Financial Review ran an article, BG seeks clearance for extra 400 CSG wells, in which it was announced:

“BG Group is seeking environmental approval to drill an additional 400 coal seam gas wells near Wandoan to help maintain gas flows to its $US20.4 billion LNG export project in Queensland once production from the initial batch of wells starts to tail off.”

“A BG spokeswman said the area involves about 50 landholders and the construction of up to three gas compression facilities, water and gas gathering pipelines, access roads and laydown areas in addition to the wells.
“The development is not expected to have any significant environmental impact, with about 94 per cent of the total permit area – or about 123,500 hectares – cleared of trees and used mainly for grazing,” he said.”

“Also included in the project are access tracks, accommodation camps and gas and water gathering lines, as well as storage ponds and pumping stations. Gas will be treated in processing plants being built as part of the initial project.”

 
 
 
 

 

The AFR article does say that this new smaller area to the existing QCLNG project is seeking environmental approval; but what approval?  According to a presentation given by Rory Ross at Shine Lawyers CSG information seminar at Wandoan on the 4^th December, any state approval will be no more than a tick and flick process with no public notification or public input. Apparently there is a trigger for any project with a footprint of above 2,000 ha to be subjected to scrutiny but no so those below. QGC doesn’t consider the project requires an EIS as it has determined that it has a 1,400 ha footprint.

QGC has to seek approval from the Commonwealth under the Environment Protection and Biodiversity Conservation Act (EPBC). I’m yet to find a link to the application but if you type into a search engine these words - EPBC QGC Detailed description of proposed action - you should find a PDF file to download.

The second image (above) is sourced from this application, the green line shows the boundary of the new ‘400 well’ area; the light grey lines shows the pre-existing farm property boundaries for the “about 50 landholder’s”.  On the map if you look to the south of the green boundary to old farm boundaries marked in red, these are farms now owned by QGC and amongst them you will see a gasfield area in green text named, Woleebee creek; this is the location for massive the processing plant as shown in the first photo.   

But how available is the Commonwealth process to public notification or input?  At the Shine Lawyer seminar the audience was informed that the application was opened to public submissions for 10 working days on the EPBC website before the document was removed from the site. Apparently the environment minister, Greg Hunt, has determined that the application has to be subjected to further additional scrutiny but to find this information is not easy.

Currently any scrutiny of these additional smaller areas is held by a thin thread of the EPBC act and specifically the water trigger amendments introduced by the former government to appease the former independent MP Tony Windsor. There have been rumblings for the water trigger removal and one vehicle for doing so could be the Productivity Commission and then this last week there was the agreement between the States and the Commonwealth for “One stop shops” for environmental approvals.

The processes for approvals for CSG projects in the past have been far from desirable; current arrangements are not ideal and what for the future? There is certainly a lot of room for improvement and while onerous, conflicting, repetitive and time consuming regulation is not needed for all productive sectors of the economy there must be in place effective scrutiny.  

The last image was prepared by Rory Ross for his presentation. The yellow triangles depict current CSG wells. Look at the saturation to the south of the proposed new “400 well’ area to the Woleebee Creek field; this is the footprint of a 750 metre well spacing, the same according to the application will go in the new area to the north. Makes a mockery of a 1,400 ha footprint within the 123,500 ha area; even Roma farmer Peter Thompson who often speaks out about the positives about CSG made this very important observation in an October interview in the Weekend Australian when speaking about reaching a value on compensation for CSG activity on his land:

“At the end of that time it was finally agreed he would be compensated for the impact on his entire land, not just the area where the gas wells were. That saw him achieve the level of payment he originally sought.

"It was bringing it to an acceptance that the work impacts the whole property - the impact is not just around the gas wells, the impact is across the whole place," Mr Thompson said.”

To meet an ongoing need for export volume of LNG the CSG companies will progressively bring into production new fields. Going by current indications they will be tacked onto the initial project piece by piece, each below the 2,000 trigger. So watch out for the 1,999 footprint.

Previous related discussions

Top ten tactics and tricks

Gas Leak Response

 

UPDATE #1- Follow up discussion

Environmental approvals - How does the current system work?

 

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Coal and gas projects can't be rushed: here's why

by Matthew Currell

New environment minister Greg Hunt recently announced 50 large coal and coal seam gas developments to be pushed through Australia’s environmental approval process, including assessment under the new federal “water trigger” introduced in early 2013.

The proposed mines are predominantly in NSW and Queensland, already sites of conflict over coal exports and CSG. A draft report from the Productivity Commission highlights the central issue: proponents of coal and CSG projects want rapid and simple assessments, while communities and environmental groups want baseline studies, more information and cumulative assessment. All of which cost time and money.
Minister Hunt’s announcement follows strong indications that the federal government wishes to speed up environmental approvals.

The decision to start assessing these 47 projects en masse and so quickly after the election seems to match the pre-election rhetoric. Greg Hunt has also suggested support for adopting an upper time limit, such as nine months for the assessment process.
However, we need to treat these assessments with caution. For many communities that will be affected by the projects the biggest concern is groundwater.

Groundwater: a sensitive resource

Most of the proposed mines will affect groundwater; in many cases from aquifers already used by people and important ecosystems. It’s not realistic to expect proper groundwater assessments be conducted in a nine-month period, or under any other form of “fast-tracking”. Let’s have a look why.
Currently, groundwater supplies about 30% of Australia’s total water use. It is an important resource in a country where most easily accessible surface water is already allocated or used. It is expected to meet a significant proportion of future water demand and help to buffer against a changing climate.
Its worth to the economy is in billions of dollars every year. Many ecosystems also depend on groundwater; recent mapping shows that groundwater is vital for ecosystems right across Australia.
Groundwater can be a highly sensitive resource for a number of reasons. In particular, the time between an impact on groundwater pressure in one area, and a corresponding change in flux of groundwater somewhere else can be lengthy. Aquifers, particularly deep aquifers, can take many thousands of years to recharge and they can be quickly to contaminated or depressurised, but more difficult to fix.

Uncertainty demands caution

Our power as a scientific community to model impacts of major projects on groundwater is still limited, despite today’s sophisticated data collection and computer modelling techniques.
All models used by hydrogeologists are characterised by uncertainty. For example, we generally can’t determine exactly by how much or how quickly one aquifer may register changes in water pressures in response to de-watering somewhere else.

Rather, a range of possible outcomes, with a certain level of confidence could realistically be provided.
Similarly, it is not easy to predict exactly how quickly pollution will move through an aquifer, and whether or when it might ultimately reach a wetland or stream. To make these predictions, extensive field studies and baseline monitoring data need to be put into our models.
In the words of one of our most eminent hydrogeology professors, Dr Craig Simmons, it is time for hydrogeologists to “level” with decision-makers and communities. Groundwater models do not give us a crystal ball to predict future impacts, and they will produce highly uncertain results if time, budget or field data are too limited.
While proponents and governments may not like to hear it, a long period of data collection and hydrogeological investigation is needed to make confident predictions with groundwater models. Proper assessment of the impacts of large coal mining and coal seam gas developments on groundwater are going to need time and resources.
The new government, proponents of major projects and communities need to bear these issues in mind. Approvals may take a long time but to protect such a precious resource as groundwater, it is worth taking it.

Author

Matthew Currell  Lecturer in Hydrogeology, School of Environmental Engineering at RMIT University

Article first published at The Conversation and republished under creative commons

CSG: Open mineral exploration holes

By Ian Hansen

If the water is removed from the coal seams as planned over such a vast area of Queensland we are going to see uncontrollable volumes of gas leak from open mineral exploration test holes and we will also witness the depletion of many of our aquifers via these holes. This will be without a doubt the greatest environmental disaster ever on inland Queensland.

There are countless thousands of these holes left open and not sealed across the state.  There is no requirement for the mineral industry to record the location or any other information about these test holes to any authority so their whereabouts, depth and formations drilled through is mostly unknown making it impossible to predict the interconnection between the aquifers by any hydrologist.

Yet the government and the department still refuse to regulate or place controls on the mineral exploration industry.  They show no respect or care for our ground water systems whatsoever.

Photo: Ian Hansen & his water drilling rig

I am a water driller and my career of 35 years has taken me across a large percentage of Queensland and I come across these holes nearly everywhere I go. I wish to raise some concerns I have with the integrity and the accuracy of the Queensland Water Commission Surat Underground Water Impact Report.

The Queensland Water Commission has made bold predictions on the impact the dewatering of the Walloons will have on other aquifers without taking into consideration these open test holes.  It is humanly impossible to calculate the effect they will have as there are no records available of these holes that may date back 50 to 60 years when portable rotary drilling rigs first became readily available. Also there is still no legislation today that requires the sealing of these holes drilled by mineral exploration drillers. Everyday another hole is drilled through these aquatards and left open their permeability is increased by an unpredictable degree.

In 1994 I was at a drilling seminar in Dalby where a senior hydrologist with the department of natural resources and mines presented a paper on the Abandonment of Test Holes and Bores.  Some of the points he made to why this is a very important practice to properly seal these holes are.

·         The elimination of physical hazards.

·         Prevent contamination of ground water.

·         Conserve yield and hydrostatic head of aquifers.

·         Prevent poor quality water beds mixing with good quality water beds.

 He also stated “All the care in the world with the construction of a production bore can be negated if test holes drilled in the vicinity are left open and not securely sealed”.

This was presented in 1994 long before the advent of coal seam gas which requires the dewatering of the Walloons to release the gas and in turn creates a huge pressure differential between the aquifers.

At every drillers meeting or seminar I have attended over the last 35 years this practice of the mineral exploration industry leaving holes open and not sealed has been mentioned and complained about, but the department and the government continue to refuse to act on this situation. 

If I as a licensed water driller were to leave a hole open and in this condition I would be prosecuted and be fined a possible $50,000 by the department because of the risks I would create to our ground water supplies. Yet the same department says it is OK for mineral exploration drillers to leave test holes in this condition.  They apparently don’t create the same risks.

The department of natural resources and mines along with the state government have over the years placed many restrictions on ground water use and also the drilling of new water bores in an effort to save our so precious ground water reserves. The most recent being a moratorium on the drilling of new water bores in towns within the Murray Darling catchment because the water system has been over allocated.

This is a very hypocritical view of the department and the government because with the dewatering of the coal seams it is only going to take one of these exploration holes that are left open through a multiple aquifer system to deplete very large volumes of water from any one system.

I have had reports from employees on exploration rigs where they have been core sampling at 800 meters and when they were finished they just pack up and drive away and leave the holes open.

It will only take one hole left open through the Condamine Alluvium to the Walloon coal seams to delete more water from the Alluvium aquifers than all the stock and domestic bores within this system put together.

One hole through the Bungle and Mooga formations, the Gubberamunda or the Springbok formations would be capable of leaking enough water to have a serious impact on any one of these aquifers with the dewatering of the coal seams.

Any holes drilled into the Huttons will also cause serious losses from this formation as the Huttons are under a great deal of pressure. At 600 meters the vertical upward pressure of the Huttons would be in excess of 800p.s.i.





























Image sourced from Surat underground water impact report

I know first-hand how tight and dense these shale layers or aquatards are as I have drilled through them many times constructing water bores. But they are of no value as a confining layer when drilled full of holes and left open.

In the Surat Underground Water Impact Report it states
"The degree of interaction between the coal units which form part of the Walloon Coal Measures and the overlying and underlying aquifers is directly influenced by the vertical permeability and the thickness of the aquatard layers."

 So as the water table is lowered within the Wallooons to release the gas there will be an uncontrollable movement of water through these aquatards via the countless thousands of holes that have been drilled and left open by the exploration drillers.

Also as the gas pressure increases due to the lowering of the water table there will be uncontrollable volumes of gas able to escape to the atmosphere via these same holes.

Therefore this Surat Underground Water Impact report has little credibility. Not until every hole is located and sealed to a satisfactory standard could any hydrology report carry any credit at all.

UPDATE #1
Follow up article - Arrow through cockatoo’s tin hut
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