140930 Final Managing Environmental And Human Health
Independent Review of Coal Seam Gas Activities in NSWManaging environmental and human health risks fromCSG activitiesSeptember 2014
www.chiefscientist.nsw.gov.au/coal-seam-gas-review
The Hon Michael Baird MPPremierMinister for InfrastructureMinister for Western SydneyParliament HouseSYDNEY NSW 2000Dear Premier,Managing environmental and human health risks from CSG activitiesAs part of the independent review of coal seam gas activities in NSW, I present a reportfocusing on the second term of reference, namely, “identify and assess any gaps in theidentification and management of risks arising from coal seam gas exploration, assessmentand production, particularly as they relate to human health, the environment and watercatchments.”In investigating how best to manage environment and human health risk, the Review took anapproach of relying on multiple sources of information. Four workshops were held, whichwere then followed with targeted meetings with key experts and industry personnel. This wassupplemented with surveying the large amount of research available in peer-reviewedjournals as well as in grey literature.The management of potential risks associated with CSG, as with other industries, can bedone with effective controls and regulation. This includes engineering solutions involvinghigh levels of industry professionalism, monitoring and modelling, and comprehensive riskassessments. The recommendations of the report reflect this finding.In presenting this report I would like to acknowledge the assistance of many people.Numerous research experts, industry personnel, government colleagues and communitymembers made themselves available to meet with my team as they worked at understandingthe issues involved in this crucial subject.Yours sincerely,Digitally signedby Mary O'KaneDate: 2014.09.3018:43:02 10'00'Mary O’KaneChief Scientist & Engineer30 September 2014Chief Scientist & EngineerGPO Box 5477, Sydney NSW 2001, Australia Tel 61 2 9338 6786www.chiefscientist.nsw.gov.au
EXECUTIVE SUMMARYThe independent review of coal seam gas (CSG) activities in NSW by the NSW ChiefScientist & Engineer commenced in February 2013. This Report is a part of that Review andfocuses on the identification and management of risk associated with CSG activities inrelation to the environment and human health. It also comments on the characteristics of aregulatory framework required effectively to manage such risks. This framework is detailed ina companion report by the Review dealing with compliance (CSE Compliance, 2014d).To examine this issue the Review conducted a series of expert workshops and meetings toidentify potential risks from CSG activities to water catchments. It was not possible todetermine in detail the likelihood and consequences (severity) of the risks as this matter arecomplex and highly dependent on local conditions (e.g. geology, hydrogeology, location,environment, etc.). These meetings highlighted the key types of potential risk, controls forthose risks and gaps in risk management.From these workshops, potential risks to the broader environment were considered to bethose resulting in impact to surface water, groundwater, soil, or air quality. The potentialenvironmental risks were grouped into four major causal ‘themes’: drilling, well integrity andfracture stimulation; seam depressurisation; spills and leaks; and produced water and solids.Potential risks to human health were considered through exposure pathways, that is, theroutes from release of a contaminant(s) to a person(s). These pathways were through water,soil and air, and indirectly in food. Dosage is critical in considering human health risks andeffects, with most pathways leading to dilution resulting in a decrease in exposure for aperson. Exposure pathways can be understood through the modelling of water and airmovement, or ecological webs, which requires knowledge of the local environment and thepotential contaminants. Potential human health risks from CSG activities are consistentlyraised as an issue of concern to the community.Published peer-reviewed studies on this issue are limited to date, and it is also difficult toconduct epidemiological studies due to the small size of the CSG industry in NSW. Furtherthe small population exposed to activities mean epidemiological studies do not havesufficient statistical power and so are unlikely to provide meaningful results at this time.However other approaches to predicting human health impacts are available such asenvironmental health risk assessments.Management of potential risks associated with CSG, as with other industries, requireseffective controls and regulation. This includes: engineering solutions – the application of technical and management approachesensures that risks such as emissions, leaks, spills, aquifer connections, etc. areminimised. This is a rapidly evolving area and it is important that NSW has access toemerging technologies and expertise monitoring and modelling, conducted with a high level of expertise and available forindependent, transparent and rigorous peer review, are important for i) understandingthe processes occurring below ground, whether in the coal seam itself, or in thesurrounding geology including the groundwater and ii) adaptive managementapproaches, whereby the activity proceeds, and can be terminated at any sign ofdeviation from expected responses (e.g. changes in water quality) comprehensive risk assessment – this involves risk identification, assessment andcharacterisation that then informs the development of management plans such asTrigger Action Response Plans. These risk assessments and management plansshould be updated progressively over the course of the project.iv
regulation of any industry needs to ensure that issues of concern in regard to risk areincorporated into planning stages and updated frequently. This is addressed in aseparate report, “Study of Regulatory Compliance Systems and Processes for CoalSeam Gas” (CSE Compliance, 2014d).As experience and technology with CSG (and other extractive industries) in NSW increases,this knowledge should be harnessed in one place and used to inform regulatory activitiesand approvals. Two recommendations to Government are made to achieve this goal.v
RECOMMENDATIONSRecommendation 1That Government develop a centralised Risk Management and Prediction Tool for extractiveindustries in NSW. This would include a risk register, a database of event histories, and anarchive of Trigger Action Response Plans. The tool would be updated annually based onGovernment and company reporting and would include information on risk management andcontrol approaches and draw on data from the Whole-of-Environment Data Repository forthe State. The risk tool would be reviewed and commented on by relevant expert andregulatory bodies. The risk tool would be used to assist with: assessing new proposals assessing compliance improving prediction capability for consequences of incidents in risk assessments improving prediction capability of risk likelihoods informing project design amendments to decrease risk levels (such as undertaken inthe Dam Safety Committee) informing the calculation of cumulative impacts flagging issues or risks that require a higher level of regulatory protection such asinclusion in legislation.Recommendation 2That Government develop a plan to manage legacy matters associated with CSG. Thiswould need to cover abandoned wells, past incomplete compliance checking, and thecollection of data that was not obtained under licence and legislation. There will also need tobe a formal mechanism to transition existing projects to any new regulatory system.vi
ContentsExecutive Summary . ivRecommendations . viCONTENTS .VIITABLES. VIIIFIGURES . VIII11.11.21.2.11.2.21.3Introduction . 1CONTEXT . 1APPROACH . 2Understanding risks and controls. 2Out of scope . 3STRUCTURE OF THIS REPORT . 422.12.1.12.1.22.22.32.42.5Managing environmental risks . 5DRILLING, WELL INTEGRITY AND FRACTURE STIMULATION . 5Well integrity . 6Fracture stimulation . 6SEAM DEPRESSURISATION . 8SPILLS AND LEAKS . 11PRODUCED WATER AND SOLIDS . 16MANAGING ENVIRONMENTAL RISKS. 2133.13.23.2.13.2.23.2.33.3Managing human health risks . 23UNDERSTANDING EXPOSURE PATHWAYS . 23UNDERSTANDING HEALTH IMPACTS . 28Health studies. 28Health studies and assessments . 28Standards for human exposure. 30MANAGING HUMAN HEALTH RISKS . 3044.14.2Conclusion and Recommendations . 33CONCLUSION . 33RECOMMENDATIONS . 34References . 36Appendices . 40APPENDIX 1CONTROLS . 40Key Regulatory Instruments . 40Select Guidelines and Policies . 40Technical Controls (TC) . 41APPENDIX 2REPRESENTATION AT RISK W ORKSHOPS AND MEETINGS. 45vii
TablesTable 1: Overview of risks from CSG activities . 13Table 2: Overview of risks associated with produced water and solids . 19Table 3: Summary of possible exposure pathways . 26Table 4: Organisations represented at risks workshops . 45Table 5: Organisations consulted in targeted meetings . 46FiguresFigure 1: Risks and controls for drilling, well integrity and fracture stimulation . 7Figure 2: Risks and controls for coal seam depressurisation . 10Figure 3: Risks and controls for spills and leaks . 12Figure 4: Risks and controls associated with produced water and solids. 18Figure 5: Schematic diagram of potential exposure pathways for contaminants oncereleased from CSG operations . 25Figure 6: The environmental health risk assessment process . 29viii
1 INTRODUCTIONPotential risks to human health and the environment are central concerns in relation to thecoal seam gas (CSG) industry in NSW. In public submissions received by the Review, themost frequently raised issue was that of potential risks to groundwater, closely followed byhuman health and the environment (CSE Initial Report, 2013).Communities that live in areas where CSG extraction is occurring, or is likely to occur, worryabout the possible long-term effects to the environment, and, by extension, the health of thecommunity. Some farmers are concerned about the potential long-term or unanticipatedeffects of CSG projects on the land or water resources that support their economiclivelihood. These concerns are echoed overseas and interstate, where there have beennumerous claims of health effects linked to unconventional gas extraction.Term of Reference 2 of the Review required the Chief Scientist and Engineer to:“identify and assess any gaps in the identification and management of risk arising from coalseam gas exploration, assessment and production, particularly as they relate to humanhealth, the environment and water catchments”This Report examines the potential risks posed by the CSG industry to the environment andhuman health. The aims are to: present a coherent picture of the potential risks identified to date, risks that are aparticular concern, and the controls currently available to mitigate risk provide guidance on characteristics of a management approach that can take fullaccount of the risks to the environment and human health from CSG activities.This report informs a separate report recommending an outcomes-based regulatoryframework which could manage risks to the environment and human health effectively (CSECompliance, 2014d).1.1 CONTEXTRisks considered here are those that could lead to impacts on the environment and/orhuman health. Impacts on the environment generally result in the pollution or depletion of anatural ecological setting or an environmental resource, such as irrigation water or farmlandsoil. Concerns about pollution of the environment are typically coupled with concerns aboutpotential risks to human and ecological health. Assessing health risks from pollution relies onunderstanding the toxicity of the pollutant and the amount that reaches the community orindividual over a given period of time.Risks can be reduced, through measures that reduce the scale of the consequences or thelikelihood of the event occurring. Adaptive management is an approach, which tracks theprogress of activities, and allows for a change or cessation of those activities as riskthresholds or triggers are realised: see CSE Information Paper: Abandoned Wells (CSEAbandoned Wells, 2014a).A key purpose of CSG-related legislation is to establish and enforce systems that monitorand control risk. Regulations, and other subordinate legislative instruments, including codesof practice, standards and guidelines, detail measures to be used for particular industries inNSW. (Appendix 1 provides a non-exhaustive list of measures for CSG). In addition, thecurrent planning approvals, licensing frameworks and activity approvals establish conditionsfor each project, based on its location and individual characteristics.1
The current regulatory system is highly complex, with many pieces of legislation andsubordinate instruments applicable to CSG projects, administered by many governmentdepartments (CSE Compliance, 2014d). During the lifetime of a project (approximately 20years for CSG), it can be difficult to change development or conditions for some licencetypes issued at the beginning, as information about the site improves or technology orcircumstances change. Further complicating matters, some agencies may make changes tothe conditions governing a project, while others may not – this is frustrating for industry andarguably does not serve the community well in addressing its concerns.1.2 APPROACH1.2.1 Understanding risks and controlsUnderstanding the potential risks posed by CSG activities has been an ongoing concern ofthe Review. The “Initial Report on the Independent Review of Coal Seam Gas Activities inNSW” (CSE Initial Report, 2013) gave an overview of risks to the environment and to humanhealth – see Chapters 7, 10 and 11.For this report, to create the list of risks associated with CSG, input was sought from expertswithin government, research organisations, industry groups, private scientific andengineering consultancies and the community through the workshop process describedbelow. A particular benefit of the workshop approach was that it brought together a diverseset of people with a wide range of experience and perspectives. Information on the controlscame in part from the workshops and in part from a series of meetings the Review held withexpert practitioners from government, research organisations and industry. A list of thoseconsulted is in Appendix 3.When examining controls, the Review primarily discusses those mechanisms by which thelikelihood or consequence of a risk is estimated, monitored or reduced. In many cases, thereare regulatory requirements that ensure a particular control is used – for example, Codes ofPractice for Coal Seam Gas Well Integrity (DTIRIS, 2012) that enforce the use of variousengineering controls. The Code of Practice itself was not considered the control for thepurposes of this Report; rather the engineering controls available are discussed. In makingthis choice, the aim is to set out clearly which control measures are available; this can thenfacilitate a discussion as to whether, or how, those measures should be enforced throughregulation. Regulatory instruments and technical controls currently available are listed inAppendix 1.A series of four workshops was convened, with a particular focus on water catchments,although other issues such as air emissions, subsidence, seismicity and possible impacts toagriculture and human health were discussed.There is no universally agreed methodology for doing risk assessments, whether for theenvironment or health. As a starting point, the Australian health and environmental riskassessment and management guidelines for drinking water supply (NHMRC & NRMMC,2011) were used to provide a risk assessment framework for use in the workshops.However, from the first workshop it was clear that characterising risk was a difficult task. Intrying to work through a traditional risk matrix, there was considerable disagreement as tohow to estimate the likelihood of risks occurring and their severity. An expert’s riskassessment depe
Potential risks to human health and the environment are central concerns in relation to the coal seam gas (CSG) industry in NSW. In public submissions received by the Review, the most frequently raised issue was that of potential risks to groundwater, closely followed by human health and the
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21 indicators of environmental sustainability. These indicators permit comparison across the following five fundamental components of sustainability: Environmental Systems; Environmental Stresses; Human Vulnerability to Environmental Stresses; Societal Capacity to Respond to Environmental Challenges; and Global Stewardship.
CHAPTER 3 AFFECTED ENVIRONMENT, ENVIRONMENTAL CONSEQUENCES, AND FINAL ENVIRONMENTAL IMPACT REPORT/ AVOIDANCE, MINIMIZATION, AND/OR MITIGATION MEASURES ENVIRONMENTAL IMPACT STATEMENT March 2015 3.2.5-2 I-405 IMPROVEMENT PROJECT Standards for the Management of Hazardous Waste, Title 23 Waters, and Title 27 Environmental Protection. Worker and public health and safety are key issues when .
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