Dear Dr Hawke,
I have the following understandings in making this submission to your inquiry:
In my former professional life as an engineer/project manager we recognised that “risk” has two essential components:
As an example you could consider that the maintenance of a Defence Force is a legitimate response to a threat to National Security that is judged to have a low to medium probability of occurring whereas the consequences of failure to deter or defeat such a threat would incur catastrophic consequences such that the risk of not maintaining a Defence Force is Unacceptable.
My comments are designed to assist your deliberations in assessing:
COMMENTS
Clauses 1 to 5 are essentially a review of the current state of knowledge, history and status of exploration and exploitation of hydrocarbon deposits. This material may not be directly relevant to risk assessment of large scale fracking using horizontal drilling technology in the NT as there are only a few wells using this approach and they are so recent that reports of the consequences, both desired and unforseen are not yet available.
There is a large amount of information available on overseas experience with large scale horizontal fracking, of which I am sure you have been made aware in other submissions.
I have no comment on clause 6, except to say that neither the available knowledge base nor the timeframe allowed your inquiry would seem to be adequate for reliable conclusions to be drawn.
Clause 7 encompasses many issues and deconstructs the process of large scale hydraulic fracking coupled with horizontal drilling in such a way as to make one to one comment difficult. With your indulgence I will develop a narrative which I trust will expose the major issues of concern, but depart from the sequence of clause 7 in the belief that you and your secretariat can “cut and paste” material you find useful.
OBSERVATION 1
The risk regime commences with the puncturing of an aquifer on the way down to the shale beds. This provides a pathway between the casing and the bore hole from the shale bed to the aquifers for both the gas and the chemical loaded water used to fracture the shale bed under high pressure.
As well as supplying water directly to current users, the aquifers are highly interconnected and they generally discharge into the rivers and streams of the NT. Contamination from entry of gas and fracking water into aquifers would range from unacceptable to catastrophic. According to the proponents of the technology, the probability of such a pathway is reduced by the insertion of concrete sealing between the casing and the bore hole and the use of high quality stainless steel casing. While it would seem that experience in the NT is insufficient to assess probability of pathways occurring, overseas experience indicates a high probability with up to 30% of sealing failures over the life of a well.
An additional factor is the stability of the limestone aquifers. The limestone is subject to erosion-the effectiveness of the material as an aquifer is due to its interconnected fissures and caverns. A concrete seal could well be left standing as the limestone naturally erodes around it. There are also reported instances of minor earthquakes and slippages within the limestone beds which, notwithstanding its high quality, would make short work of a stainless steel casing.
Point 1
It is for your consideration that probability of failure of the seal between the casing and the bore hole must be vanishing low, not over the life of the well but permanently. The community has reasonable expectations that there will never be intrusion of gas and fracking water over a period of time well in excess of the life of array of wells
OBSERVATION 2
The previous section dealt with pathways from the shale bed to the aquifers and the probability of contamination which would be impossible (impractical-whatever degree of difficulty you care to nominate) to remediate.
This paragraph deals with surface contamination. We have all seen images of household taps bursting into flame and bores alternating between water and gas. The consequent loss of water as an essential but now unusable resource is clearly an unacceptable consequence. Although proponents of exploitation of the gas bearing strata are reported as denying causality. What would be difficult deny is the hazard presented at the surface by the expulsion of water bearing chemicals from bores. I understand that 25megalitres is required to achieve the fracturing which is required by the process to release the gas. Whether the return to the surface of all or part of 25megalitres per bore is deliberate or incidental, it does not take much imagination to realise that management in a production bore field of the volume of water containing chemicals and other ingredients to provoke fracturing is not a trivial task.
The weather pattern in the NT is characterised by 6-8
months of no rain-the Dry- followed by 4-6 months of the Wet during
which rain comes in deluge-like quantities and is unpredictable in its
location and concentration. The ensuing flooding is no respecter of
retaining dams or similar works to store contaminated water and the
probability of that water being carried into the rivers and groundwater
is very high. The consequences would be widespread, unpredictable and
catastrophic.
Every Wet the NT community witnesses the efforts by ERA to
control the stored contaminated water from the uranium mine at Jabiru,
while the communities who are dependent on the Daly River catchment
area are aware of the gigalitres containing leached heavy metals at the
Mt Todd goldmine. The solution being implemented at Mt Todd is to take
advantage of high flows in the Edith River when and if they occur
during the Wet and to release a measured quantity just sufficient to
raise the concentration of heavy metals up to but not exceeding the
international standard. Put that succinctly, the Mt Todd problem does
appear fraught with uncertainty.
Point 2
It is for your consideration that the retention of chemical laden water used for the fracturing process and recovered to the surface poses a complex and unprecedented challenge in those parts of the NT which are subject to the annual Wet or, as in the Centre, occasional flooding. The probability of contaminated water entering any of the major river systems in the NT must be rated as high and the consequences unacceptable.
OBSERVATION 3
It has been reported that the under the terms of an exploration licence, the explorer does not require a water allocation in order to obtain water, up to 25megalitres per bore, needed to fracture the shale bed. At a time when Australia is witnessing the degradation of the Murray-Darling rivers systems and agencies in the NT have been working on a Water Plan which will avoid the over allocation that bedevils the Murray-Darling system the absence of conditions on sources, quantity and management of water in the exploration licences constitutes the admission into the exploration licence of an unnecessary risk. Since the government is obliged to issue a production licence to any explorer which discovers gas in commercial this risk would flow on to the production licence.
Point 3
It is for your consideration that the issue of
unrestricted access to water for the purpose of fracturing shale beds
admits into the exploration and production phases an unnecessary risk
of uncontrolled exploitation of water resources. The community has a
reasonable expectation that projected water usage should be included in
the NT Water Plan and actual usage be reported to the government.
SUMMARY
This submission deals with three major issues.
The government in establishing your inquiry shows awareness of the
community’s concerns. My observation is that the government has
recognised that previous attempts to allay these concerns have been
nugatory and have instead increased in some people their mistrust of
spokespersons from both industry and government. The people are asking
for definite answers to their concerns and are suspicious when they are
treated with apparent disrespect and are given answers which are
inconsistent and evasive.
My own view, based on many years of engineering management
experience, is that the totality of the system associated with
exploration and exploitation of shale gas in the NT is unprecedented
and complex. The information, knowledge and experience does not exist
that is necessary for exceptionally low risk furtherance of the social,
economic and environmental consequences of shale gas developments. In
such circumstances the precautionary principle is indicated and in that
vein may I conclude in the hope that your overall recommendation to
the NT Government is festinate lente.
MY CREDENTIALS
In preparing the above submission, I draw on my experience as Director, Defence and Aerospace Industry Development from 1987 to 1991 with the South Australian Government and before that my experience in the transfer to industry of projects initiated in the Defence Science and Technology Organisation in pursuit of the Federal Government policy to develop the capability of the private sector of Australian defence industry.
I am well aware, as I am sure you are, that politicians, bureaucrats and industry march to the sound of different drums. In the best of circumstances, given good will, time and knowledge, it is possible to synchronise the drummers. Unfortunately in the case of hydraulic fracturing of shale gas strata there is insufficient knowledge; the government has rushed the process, no doubt encouraged by industry, and goodwill has been forfeited.
I wish you well in restoring goodwill, advancing the knowledge base and promoting a more measured approach
Errol Lawson BE, PhD