Amendment Notice 1 - der.wa.gov.au · Date of Amendment 23 February 2017 ... sampled by Intertek on 19th December ... The Licence Holder was provided with the draft Amendment Notice

Licence L8766/2013/1 File No: 2013/003354 Template: 1.3 1

Licence Number L8766/2013/1

Licence Holder Empire Oil Company (WA) Limited

ACN 009 475 423

Registered business address 229 Stirling Hwy

CLAREMONT WA 6010

Date of Amendment 23 February 2017

Prescribed Premises Category 10: Oil or gas production from wells

Premises Red Gully Processing Plant Wannamal Road West BOONANARRING WA 6503 Being Lot 5653 on Plan 206748

Amendment

The Chief Executive Officer (CEO) of the Department of Environment Regulation (DER) has amended the above licence in accordance with section 59 of the Environmental Protection Act 1986 as set out in this Amendment Notice.

Date signed: 23 February 2017

Caron Goodbourn

Acting Manager Licensing, Process Industries

an officer delegated under section 20 of the Environmental Protection Act 1986 (WA)

Amendment Notice 1


Amendment Notice

This notice is issued under section 59 of the Environmental Protection Act 1986 (EP Act) to amend the licence issued under the EP Act for a prescribed premises as set out below. This notice of amendment is given under section 59B(9) of the EP Act.

The following DER Guidance Statements have informed the decision made on this amendment [delete Guidance Statements which have not been applied]:

Guidance Statement: Regulatory Principles (July 2015)

Guidance Statement: Setting Conditions (October 2015)

Guidance Statement: Decision Making (November 2016)

Guidance Statement: Risk Assessment (November 2016)

Guidance Statement: Environmental Siting (November 2016)

Amendment Description

The Red Gully Processing Facility (RGPF) processing plant processes gas and liquids piped from the Gingin West-1 and Red Gully-1 feed wells to produce purified gas and condensate. Purified gas is transported via a pipeline to a connection point on the Dampier Bunbury Natural Gas Pipeline (DBNGP) receival facility owned and operated by Dampier Bunbury Pipeline (DBP).

Currently, RGPF includes one wastewater evaporation pond that is 50m x 50m x 1m in size with a maximum holding capacity of 2.5ML (excluding the 300mm freeboard) for the storage and evaporation of treated produced water. The pond was designed to hold all rainfall, and wastewater including a 1 in 100 year storm event of 24 hour duration without overtopping.

Since March 2016 RGPF reported an increase in produced water due to formation water breakthrough. Produced water requiring disposal, is predicted to continue to trend upwards to 29.01 ML per year.

This Amendment Notice is the result of a Licence Holder (L8766/2013/1) initiated amendment to approve works and relates to the construction of two additional evaporation ponds of 140m x 83m x 0.68m (excluding freeboard) each in size with a total maximum holding capacity of 15.8ML.

Location, environmental siting and potential receptors

Table 1: Receptors and distance from prescribed premises

Residential and sensitive premises Distance from Prescribed Premises

Nearest resident The nearest residents are located 1.29km from the proposed works

Table 2: Environmental receptors and distance from prescribed premisesError! Reference source not found.

Environmental receptors Distance from Prescribed Premises

Groundwater (Yarragadee formation) Approximately 152mbgl

Boonanarring Nature Reserve 10m from the south eastern corner of the evaporation pond batter boundary


Risk Assessment

Tables 3 and 4 below describe the Risk Events associated with the amendment consistent with the Guidance Statement: Risk Assessments. Both tables identify whether the emissions present a material risk to human health or the environment, requiring regulatory controls.

Table 3: Risk assessment for proposed amendments during construction

Risk Event

Material Risk

Reasoning Source/Activities

Potential Emissions

Potential Receptors

Potential Pathway

Potential Adverse Impacts

Category 10: Oil or gas

production from wells

Construction of 2 HDPE lined ponds (140m x 83m x 0.68m) each.

Dust: associated with construction activities on the premises.

Residence 1.29km from the proposed works. Boonanarring Nature Reserve 10m from the south eastern corner of the evaporation pond batter.

Air Health and amenity impacts.

No

The Delegated Officer considers that the separation distance between the source and potential receptors is sufficient to ensure there are no adverse impacts on potential receptors. Works are temporary and will be of a short duration. The Environmental Protection (Noise) Regulations 1997 apply.

Noise: associated with construction activities on the premises.

Table 4: Risk assessment for proposed amendments during operation

Risk Event

Material Risk Reasoning Source/Activities

Potential Emissions

Potential Receptors

Potential Pathway

Potential Adverse Impacts

Category 10: Oil or gas

production from wells

Waste and leachate :

associated with seepage and leaks of ponds and overflow of ponds.

Treated produced water (saline and hydrocarbon contamination).

Groundwater (152mbgl) and Boonanarring Nature Reserve 10m from the south eastern corner of the evaporation pond batter.

Soil surface and groundwater.

High salinity of the wastewater will have an adverse effect to the health and survival of vegetation.

No

The works will increase the total wastewater holding capacity from 2.5ML to 18.3ML and pond surface area for evaporation from 2500m

2 to 25,740m

2

Existing condition L1.3.2 requires the Licensee to ensure that the evaporation pond is maintained with a minimum top of embankment freeboard of 0.3m.


Depth to ground water is ≥152mbgl In the event of overtopping, drainage gradient is away from the Boonanarring Nature Reserve (Andre Dorrius- Survey Dynamics). The Evaporative Pond for RGPF was sampled by Intertek on 19th December 2016 for hydrocarbon analysis, analysis are as follows: Benzene – 0.166mg/l, Toluene – 0.154mg/l, Ethylbenzene - 0.012mg/l, o-Xylene – 0.068mg/l, m, p – Xylene – 0.016mg/l, Extractable Organic Matter – 26.1 mg/l and Total Petroleum Hydrocarbons was not detected. The ponds are designed to prevent overland stormwater flows from entering the pond – see schedule 1. Water balance calculations done by EDG consulting engineers (Empire Oil & Gas NL red Gully Pipeline & Production Facility Evaporation Pond sizing – Calculation Report – Document ID: 6717126-21100-00001- dated 08/02/2017) using the monthly treated produced water rate and the pan coefficient rate which integrates the effects of several climate elements such as temperature, humidity, rain fall, solar radiation, surface area, wind and combined salinity factor, conclude a net annual evaporation rate of 53.67ML with total inputs of 29.01 ML therefore demonstrating that the ponds are adequate in size to evaporate all produce water.

Infrastructure hazards

N/A Terrestrial fauna.

Wildlife access to ponds with steep and slippery banks.

Potential entrapment and drowning. Entrapment of large terrestrial fauna may damage liner.

No The pond will be fitted with fauna egress matting and ramps which allow trapped wildlife to escape from lined pond.


Decision

The Delegated Officer has considered the environmental risk of constructing two additional evaporation ponds therefore increasing the total treated produced water evaporation ponds holding capacity from 2.5 ML to 18.3ML. During the assessment the overall risk (as assessed using the risk criteria stipulated in Appendix A) of treated produced water impacting the quality of groundwater and/or surrounding ecosystem during normal operations is considered to be Low.

Applicant controls for the construction of the works is added to the licence as conditions L4.2.1 – L4.4.3 to ensure that the treated water evaporation ponds are built according the appropriate design and construction standard.

Condition L1.3.1 on the Licence capture premises operation relating to the evaporation pond.

The Delegated Officer considers the construction of the ponds to be an improvement to the operations of the premises based on the risk assessment above and that the ponds are adequate in size for all produced water generated on site to be contained and evaporated based on the water balance provided in the application. Refer to Table 3and 4 to the Delegated Officers decision.

Amendment History

Instrument Issued Amendment

L8766/2013/1 23/02/2017 Amendment Notice 1 Licence amendment to construct two additional evaporation ponds.

Licence Holder’s Comments

The Licence Holder was provided with the draft Amendment Notice on 22 February 2016. Comments received from the Licence Holder have been considered by the Delegated Officer as shown in Appendix 2.

Amendment

1 The following definition is added to the interpretation section Condition 1.1.2: “Annual Audit Compliance Report” means a report in a format approved by the CEO as presented by the Licence Holder or as specified by the CEO from time to time and published on the Department’s website; “produced water” means water that is produced as a byproduct along with the oil and gas

2 Conditions L1.3.1 and L1.3.2 of the Licence is amended by the deletion of the text shown in strikethrough below and the insertion of the red text shown in underline below.

1.3.1 The Licence Holder shall ensure that produced water is only discharged into the lined evaporation ponds as per the specification in Table 1.3.1.

Table 1.3.1: Containment infrastructure

Containment Cell Material Requirements

Evaporation ponds 1, 2 and 3

Treated produced water.

Lined with High Density Polyethylene (HDPE) Geomembrane with 2mm ≥ 1.5mm thickness and a density of 0.94 g/cm3 over the soil base layer to achieve a permeability of at least 10

-9 m/s.

Fauna egress matting and ramps maintained to allow trapped wildlife to escape from lined ponds.

Maintain a minimum top of embankment freeboard of 300mm.


Condition L 1.3.2 The Licensee shall ensure that the evaporation pond is maintained with a minimum top of embankment freeboard of 300 millimetres.

3 The licence is amended by the insertion of the following Conditions 4.2:

4.2 Works

4.2.1 Construction of Ponds (contaminated stormwater and produced water)

In relation to the construction of the Ponds infrastructure, the Licensee must construct the infrastructure in Column 1 at the location in Column 3 in accordance with the requirements set out in Colum 2 as illustrated in Table 5 below.

Table 5: Infrastructure design and construction requirements

Column 1 Column 2 Column 3

Infrastructure Requirements (design and construction) – Proponent controls

location

I. Stage one: installation of Evaporation Pond 2 with storage capacity of 7.9ML

II. Stage two: installation of Evaporation Pond 3 with storage capacity of 7.9ML

construct each pond according final design, approximately 140m x 83 m x 0.68m to achieve a minimum holding capacity of 7.9 ML excluding 300mm freeboard

the base material for the ponds to include compacted sand/ screened material to avoid any localised pressure points from any underlying materials.

has fauna egress matting and ramps installed to allow trapped wildlife to escape from lined ponds.

designed to prevent stormwater from entering the ponds

map in Schedule 1

HDPE liner minimum thickness for the lining material is ≥1.5 mm thick HDPE(High Density Poly Ethylene).

chemically compatible with light aromatic fractions from produced water and contaminated stormwater.

all seams and joins must be continuous and panels and must overlap by approximately 100mm.

required life of HDPE liner to be at least 10 years.

all welded seams to be tested and confirmed as being impermeable to water.

Inflow pipe to the evaporation ponds

under the immediate location of each of the pond inflow pipes, an additional layer of equivalent HDPE material is to be installed and maintained.

4.3 Infrastructure Design and Construction Requirements

4.3.1 The Licence Holder must carry out the Works within the Premises in accordance with the requirements set out in Schedule 2.

4.3.2 Subject to Condition 4.3.3, on completion of the Works, the Licence Holder must provide to the CEO engineering or building certification from a suitably qualified professional confirming each item of infrastructure or component of infrastructure specified in column 1 with the requirements specified in column 2, as set out in Table 5 have been constructed with no material defects.


4.3.3 The Licence Holder must not depart from the requirements specified in column 2 of Table 5 except:

(a) where such departure does is minor in nature and does not materially change or affect the infrastructure; or

(b) where such departure improves the functionality of the infrastructure and does not increase risks to public health, public amenity or the environment;

and all other Conditions in this Licence are still satisfied.

4.3.4 If Condition 4.3.3 applies, then the Licence Holder must provide the CEO with a list of departures which are certified as complying with Condition 4.3.3 at the same times, and from the same professional, as the certifications under Conditions 4.3.2.

4.4 Information

4.4.1 The Licence Holder must submit a Compliance Report to the CEO within 90 days following the construction of the works and prior to commissioning of the same indicating the extent to which the Licence Holder has complied with the Works Conditions in this Licence.

4.4.2 The compliance document must:

(a) certify that the works was constructed in accordance with the conditions of the works approval; and

(b) be signed by a person authorised to represent the Licence Holder and contain the printed name and position of that person within the company.

4.4.3 The Licence Holder must comply with a CEO Request, within 7 days from the date of the CEO Request or such other period specified in the CEO Request.

4. Schedule 2: Reporting &notification forms- the Annual audit compliance report proforma is deleted

Appendix 1: Key Documents Document Title In text ref Availability

1 Empire Oil & Gas NL

Red Gully Processing Facility

Requirement for additional

Evaporation Ponds Dec 8

2016

accessed at http://www.der.wa.gov.au

2 Application for Amendment L8766/2013/1 –

Empire Oil & Gas (WA) Limited

Application for amendment to

Licence L8766/2013/1

DER records (A1341160)

3 DER, July 2015. Guidance Statement:

Regulatory principles. Department of

Environment Regulation, Perth.

DER 2015a

accessed at http://www.der.wa.gov.au

4 DER, October 2015. Guidance Statement: Setting conditions. Department of Environment Regulation, Perth.

DER 2015b

5 DER, November 2016, Guidance

Statement: Environmental Siting.

Department of Environment Regulation,

Perth.

DER 2016a

6 DER, November 2016. Guidance

Statement: Risk Assessments. Department

of Environment Regulation, Perth.

DER 2016b

7 DER, November 2016. Guidance Statement: Decision Making. Department of Environment Regulation, Perth.

DER 2016c

http://www.der.wa.gov.au/

http://www.der.wa.gov.au/


8 Empire Oil & Gas NL- Red Gully Pipeline & Production Facility- Evaporation Pond Sizing – Calculation Report – EDG Consulting Engineers - Document ID: 6717126-21100-00001- Dated 08/02/2017

Red Gully requested additional information


9 E-Mails dated 13/02/2017- Dust suppression

Red Gully Dust Suppression DER records (A1377679)

10 E-Mail dated 13/02/2017 – Andre Dorrius – Survey Dynamics

Red Gully- Pond in relation to Nature Reserve


11 Intertek Geotech – Ref PO 4500000204- Pond water analysis

Red Gully requested additional information


Appendix 2: Summary of Licence Holder Comments The Licence Holder was provided with the draft Amendment Notice on 22 February 2016 for review and comment. Comments received from the Licence Holder have been considered by the Delegated Officer as shown in the table below.

Comments received DER consideration of risk

The proponent indicated an error in Table 2, 3 & 4 with respect to the distance of the ponds to the Nature Reserve. The distance is 10m from the batter of the pond.

The Delegated Officer considered the change and amended the tables accordingly


Schedule 1: Maps and Drawings Attachment 1: Evaporation ponds


Attachment 2: Survey Drawing of Proposed Locations


1. Schedule 2: Works

The Works to be carried out on the Premises are specified in Table 6

Table 6: Works to be carried out on the Premises

Item Works Specifications/Drawings

1

Stage one: construct Evaporation Pond 2 with a minimum storage capacity of 7.9ML.

All, including Application Documents, Supporting Information (Appendix 1) and Drawings and Appendices as per Schedule 1

2

Stage two: construct Evaporation Pond 3 with a minimum storage capacity of 7.9ML


3

Prepare the subgrade/pond floors for the installation of HDPE liner (≥1.5mm thick)liner


6

Complete an ‘As constructed’ survey. All, including Application Documents, Supporting Information (Appendix 1) and Drawings and Appendices as per Schedule 1


Appendix A – Risk Criteria

Likelihood

Consequence

Insignificant Minor Moderate Major Severe

Almost Certain Moderate High High Extreme Extreme

Likely Moderate Moderate High High Extreme

Possible Low Moderate Moderate High Extreme

Unlikely Low Moderate Moderate Moderate High

Rare Low Low Moderate Moderate High

Likelihood Consequence

The following criteria has been used to determine the likelihood of the risk / opportunity occurring.

The following criteria has been used to determine the consequences of a risk occurring:

Public Health Ecosystem/ Environmental

Almost Certain

The event is expected to occur in most circumstances

Severe Loss of life

Exposure to hazard with permanent prolonged adverse health effects expected to large population

Health criteria is significantly exceeded

Irreversible impact to significant high value or sensitive ecosystem expected

Irreversible and significant impact on a wide scale

Total loss of a threatened species expected

Ecosystem criteria is significantly exceeded

Likely The event will probably occur in most circumstances

Major Exposure to hazard with permanent prolonged adverse health effects expected to small population

Significant impact to amenity for extended periods expected to large population

Health criteria is exceeded

Long-term impact to significant high value or sensitive ecosystem expected

Long-term impact on a wide scale

Adverse impact to a listed species expected

Ecosystem criteria is exceeded

Possible The event could occur at some time

Moderate Exposure to hazard with short-term adverse health effects expected requiring treatment

Impact to amenity expected for short periods to large population

Health criteria is at risk of not being met

Minor and short-term impact to high value or sensitive ecosystem expected

Off-site impacts at a local scale

Ecosystem criteria is at risk of not being met

Unlikely The event is unlikely to occur

Minor Exposure to hazard with short-term adverse health effects expected

Impact to amenity expected for short periods to small population

Health criteria are likely to be met

Moderate to minor impact to ecosystem component (physical, chemical or biological)

Minor off-site impacts at a local scale

Ecosystem criteria are likely to be met

Rare The event may only occur in exceptional circumstances

Insignificant No detectable impacts to health

No detectable impacts to amenity

Health criteria met

None or insignificant impact to ecosystem component (physical, chemical or biological) expected with no effect on ecosystem function

Ecosystem criteria met