Golden Beach Gas Project Response to submissions received on the Project EES Environment Effects Act 1978
GB Energy (VIC) Pty Limited ABN 63 615 553 010
Golden Beach Gas Project
Table of Contents
1. Introduction ...... 3 1.1 Background ...... 3 1.1.1 Environment Effects Act 1978 ...... 3 1.1.2 Environment Protection and Biodiversity Conservation Act 1999 ...... 4 1.1.3 Exhibition of the EES ...... 4 1.2 Purpose of this document ...... 4 2. Submissions ...... 5 2.1 Overview ...... 5 2.2 Responses to submissions ...... 6 2.2.1 Submissions 1, 2, 3 and 7 – Project need and climate change ...... 6 2.2.2 Submission 4 – Wellington Shire Council ...... 7 2.2.3 Submission 5 – Environment Protection Authority ...... 8 2.2.4 Submission 6 – Individual submitter, multiple key issues ...... 9 2.2.5 Submission 8 – The CarbonNet Project ...... 9 2.2.6 Submission 9 – DELWP Gippsland Region ...... 9 2.2.7 Submission 10 - Australasian Native Orchid Society (Victorian Group) Inc ...... 10 2.2.8 Submission 11 – Individual submitter, multiple key issues ...... 11 2.2.9 Submission 12 – Individual submitter, multiple key issues ...... 13 2.2.10 Submission 13 – West Gippsland Catchment Management Authority ...... 14 3. Conclusion ...... 14
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 2
Golden Beach Gas Project
1. Introduction
1.1 Background GB Energy (VIC) Pty Ltd (GB Energy), as operator of retention lease VIC/RL1(V), is developing the Golden Beach gas field located in the Gippsland Basin approximately 4 km offshore from the Ninety Mile Beach coast line and close to the Golden Beach township. The field was originally discovered in 1967. The Golden Beach Gas Project (Project) includes the drilling and completion of two offshore wells in Victorian waters, and the construction of high pressure gas pipeline(s) connecting the wells to the east coast gas market in the vicinity of Longford, Victoria. The proposed infrastructure includes: two offshore wells with installation of subsea production systems, Christmas trees (XMTs) and wellheads high pressure steel gas pipeline(s) and associated infrastructure from the subsea wellheads to existing operating gas transmission infrastructure at Longford in Victoria. Pipeline infrastructure would include: o a subsea raw gas pipeline and umbilical from the offshore wellheads to a shore crossing facility o a shore crossing facility which would enable for the safe and efficient operation of the wells and raw gas pipeline o a buried onshore raw gas pipeline from the shore crossing facility to the gas compressor station o a gas compressor station to dry and compress raw gas from the offshore field to deliver sales quality gas o a buried onshore sales gas pipeline from the gas compressor station to the existing Victorian Transmission System (VTS) and the Eastern Gas Pipeline (EGP) at Longford o a metering facility adjacent to Jemena’s Longford Compressor Station, for the commercial and operational metering of the flows of gas to the east coast gas market. The development would occur in two phases, with the first phase being the production of gas. This would involve extracting a portion (approximately 40 - 45 petajoules) of the gas currently within the reservoir. The second stage would be the conversion of the field into a gas storage facility, providing an initial withdrawal capacity of up to 250 terajoules per day.
1.1.1 Environment Effects Act 1978 The Project was referred by GB Energy to the Minister for Planning under the Environment Effects Act 1978 (EE Act) on 7 August 2019 describing the potentially significant effects of the Project following a preliminary assessment of the proposed Project. On 8 September 2019, the Minister for Planning requested that GB Energy prepare an Environment Effects Statement (EES) under the EE Act to assess the potential environmental effects of the Project and to inform the Minister’s assessment of the Project and the approvals required for the Project. The Minister’s reasons for making this decision included that the Project works have ‘the potential for a range of significant environmental effects’ including on: offshore marine biodiversity values Aboriginal cultural heritage values onshore biodiversity values including Lake Reeve which is part of the Gippsland Lakes Ramsar site.
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 3
Golden Beach Gas Project
1.1.2 Environment Protection and Biodiversity Conservation Act 1999 On 22 November 2019 under delegated authority from the Minister for the Environment, the Department of Agriculture, Water and the Environment (DAWE) made a decision that the Project is a controlled action under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) and would require assessment and a decision about whether approval should be given under the EPBC Act. The Minister considered that the Project would likely have a significant impact on the following: Ramsar wetlands Listed threatened species and communities Listed migratory species The Project will be assessed under a bilateral agreement under the EE Act.
1.1.3 Exhibition of the EES Following preparation of the EES in accordance with the scoping requirements provided for the Project in May 2020, GB Energy sought authorisation from the Minister for Planning on 8 October 2020 to place the EES on public exhibition in accordance with the amended EES procedures and requirements for the Project dated 13 September 2020. The Works Approval under the Environment Protection Act 1970 (WAA) and Pipeline Licence Application under the Pipelines Act 2005 (Application) were also exhibited with the EES. The Minister authorised the EES to be placed on exhibition on 18 October 2020 for a period of 30 business days with exhibition commencing on Monday 26 October 2020. The EES, the Application and the WAA were placed on exhibition for public comment from Monday 26 October until 11.59pm on Monday 7 December 2020. The following advertisements/notices were placed in newspapers with local, Victorian, and Australian distribution areas for the expression of interest and exhibition of the EES (and approval applications): Expression of interest to request copy of EES The Australian: 8 October 2020 Herald Sun: 8 October 2020 Gippsland Times: Tuesday 6 October Exhibition of EES The Australian: Thursday 22 October 2020 Herald Sun: Thursday 22 October 2020 Gippsland Times: Friday 23 and Tuesday 27 October 2020 Notices in accordance with section 32 of the Pipelines Act were issued to landowners, stakeholders, Ministers, departments, authorities and persons as specified under the Pipelines Act and by the delegate of the responsible Minister.
1.2 Purpose of this document This document has been prepared to respond to issues raised by submitters through the public exhibition of the EES. In accordance with the Ministerial guidelines for assessment of environmental effects under the Environment Effects Act 1978, Seventh edition 2006, the proponent should produce a document responding to the issues raised in submissions on the EES.
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 4
Golden Beach Gas Project
2. Submissions
2.1 Overview Twelve (12) submissions were received during the public exhibition of the EES (and approval application documentation) and one (1) submission was received and accepted after the closing of the public exhibition period. Six (6) from individual members of the Victorian community Five (5) from government organisations Two (2) from non-government organisations. No submissions were received from affected landowners or occupiers of the land subject to the Application exhibited with the EES (other than Wellington Shire Council in its capacity as local council and not as a landowner) or from the local Golden Beach community. GB Energy has worked extensively with landowners and the local community to provide comprehensive and transparent information in relation to the Project, the EES process and the Application. Summary of submissions:
No. Submitter type To be heard Key issues
1. Individual No Project need & climate change
2. Individual Yes Project need & climate change
3. Individual No Project need & climate change
4. Wellington Shire Council No Traffic management & road impacts Community & stakeholder engagement Construction timing Acid sulphate soils Native vegetation removal Water discharges Community fund Local employment and procurement
5. EPA Yes Accidental releases to marine environment Guideline updates Duration of waterway rehabilitation monitoring Groundwater depressurisation Acid sulfate soils (incl. wet trenching) Contaminated soils Noise and vibration Assessment of Works Approval Application
6. Individual No Project need Four key risks: Climate change Ecological damage Water security Community wellbeing
7. East Gippsland Climate No Project need & climate change Action Network
8. The CarbonNet Project No Cumulative impacts
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 5
Golden Beach Gas Project
No. Submitter type To be heard Key issues
9. DELWP Gippsland No Native vegetation Region Native vegetation regulations
10. Australasian Native No Native vegetation – threatened orchids Orchid Society (Victorian Group) Inc
11. Individual Yes Climate change Radioactive material considerations Air Quality Gas Quality Noise and vibration Dutson Downs
12. Individual No Cumulative impacts Hydrology and hydrogeology in operations Outer dune barrier - subsidence Contaminated land (Acid sulfate soils and PFAS)
13. West Gippsland No Nil – notes on EES submission Catchment Management Authority
2.2 Responses to submissions GB Energy acknowledges the submissions received in response to the Project’s EES and provides the following responses. All submissions are available on the Engage Victoria website.
2.2.1 Submissions 1, 2, 3 and 7 – Project need and climate change In summary, submissions 1, 2, 3 and 7 provide comment as to the need for gas (or fossil fuels) over renewable energy, along with climate change issues. Project need Chapter 2 of the EES provides a detailed rationale for the Project. The Project would materially benefit the Victorian energy market and would provide: o critical gas supply o strategic storage infrastructure. Once in operation, the Project would directly address market constraints by introducing new gas supply. Over the longer term, a reliable and economically efficient means of storing energy would also enhance grid reliability and renewable energy initiatives. Gas storage provides the platform to enable gas to be the reliable energy companion to renewables. As Australia transitions to a low emissions economy underpinned by renewable energy, natural gas will play a critical role by efficiently supporting the intermittency of solar and wind energy. This would help provide stable and secure energy supply while other technologies such as hydrogen and batteries are being scaled up (Finkel, 2020). Commercial agreements for the sale of the gas produced and for ongoing storage have been executed with a domestic energy retailer, demonstrating the need for the Project in the current east coast market.
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 6
Golden Beach Gas Project
Climate change Chapter 14 of the EES sets out the Project’s impact in the context of greenhouse gas emissions. In addition, we refer you to section 8 of the WAA. The Project’s greenhouse gas emissions will only provide a minor contribution to Victoria’s annual greenhouse gas emissions, while supporting a transition to renewable energy. The Project will account for less than 0.06% of Victoria’s annual greenhouse gas emissions through construction, 0.05% through production and storage, and 0.02% from decommissioning.
2.2.2 Submission 4 – Wellington Shire Council Wellington Shire Council was a member of the Technical Review Group (TRG) during the EES process and its submission reiterates the key points that were discussed through its participation in the TRG. Responses to each of the issues raised are provided below. Road impacts and reinstatement A Traffic Management Plan (TMP) will be prepared for the Project in accordance with Mitigation Measure (MM) MM-TP1 including consultation with Wellington Shire Council. Agreements/MOU will be entered into in parallel with the TMP development. GB Energy undertook a site visit with Wellington Shire Council on 16 June 2020 to discuss preliminary requirements to be considered in the early phase of the Project (and considerations in the EES). Mitigating social and environmental impacts o A comprehensive community and stakeholder engagement plan will be prepared by GB Energy prior to commencement of construction (See MM-SE01) o A draft Construction Environmental Management Plan (CEMP) has been prepared in consultation with DELWP Pipeline Regulation (see Attachment 5 of the Pipeline Licence Application). This CEMP will be updated to reflect all required mitigation measures with the appointed contractor and approved prior to construction (pursuant to the Pipelines Act). o A complaint handling process will be implemented by the Project (see MM-SE02) o Scheduling of construction activities will take into account peak holiday periods and community events at Golden Beach (see MM-SE04) o An Acid Sulfate Soil Management Plan (ASSMP) will be prepared for areas of acid sulfate soils, including the Lake Reeve crossing (see MM-CO05) o Opportunities to further avoid or minimise impacts to native vegetation will continue to be pursued by the Project prior to securing relevant offsets and native vegetation removal (and commencement of construction activities). See MM-FF01. o Discharges at the Gas Compressor Station will be in accordance with the EPA Works Approval and water quality requirements (see MM-CO10) Optimising community outcomes GB Energy will continue to work with WSC in relation to the community benefit fund, including level of their involvement and governance of the fund (and associated community spending). Optimising economic outcomes See MM-SE05. GB Energy will develop a recruitment and procurement plan (along with the appointed contractor) to maximise local employment and procurement opportunities. Consulting Department of Defence The Department of Defence will be included in the Stakeholder engagement plan (see MM- SE01) and engaged through detailed design to ensure structures will not pose a threat to Defence operations.
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 7
Golden Beach Gas Project
2.2.3 Submission 5 – Environment Protection Authority Adopting the numbering used in Submission 5, GB Energy responds as follows: Section 5.4.1 – GB Energy accepts the recommendation made to amend section 23.2 as suggested. Section 5.4.2 - GB Energy accepts the recommendation made to amend section 23.2 as suggested and the recommendation with respect to the CEMP. Section 6.1.2 - GB Energy will prepare an Oil Pollution Emergency Plan (OPEP) in accordance with MM-ME54. GB Energy will also prepare Environment Plans (EPs) and Safety Cases in accordance with the OPGGS Act (Vic) for assessment and approval by relevant regulators (DJPR & NOPSEMA respectively). These will include measures to avoid collision and emergency response protocols. Section 6.2.1 - GB Energy accepts the recommendation made to amend MM-FF07 as suggested. Section 6.2.2 – Monitoring and maintenance of easement (based on respective land uses and areas of sensitivity identified in an Environmental Line List) will be included in the Operational Environmental Management Plan in accordance with the Pipelines Act, however GB Energy does not believe an arbitrary 3-year term is required. Rehabilitation Plans will be agreed with landowners and land will only be released upon landowner satisfaction. Also note MM-FF23 provides for the preparation of a Coastal Saltmarsh Management Plan including ongoing monitoring for Lake Reeve. Section 6.3.1 – Other than those discussed in the EES, no other GDEs were identified as being potentially impacted by the Project. o Stygofauna – Although stygofauana may exist in non-karstic aquifers, these are more likely to be in higher porosity alluvial sediments in areas of high recharge where nutrients and oxygen are most available (for example adjacent/nearby surface water). A regional baseline stygofauna survey (Hocking et al, 2020) carried out in the onshore Gippsland Basin (including GBE Project area) found low abundance of stygofauna compared to other state surveys. Stygofauna was found in one shallow bore within the alluvial floodplain consisting of sand, silt and gravel; and associated with Mitchell River. For the GBE Project, where the proposed pipeline intersects groundwater and alluvial/swamp deposits of Lake Reeve the pipe is to be laid wet, minimising effects on groundwater. Away from Lake Reeve the geology consists of fine grained silts, clays and sands of the inland and coastal dunes. This environment is expected to have limited potential for groundwater to be intersected, or stygofauna to be present. Stygofauna is unlikely to occur in the Lower Aquifer System given the depth and distance along groundwater flow paths (i.e. distance from recharge areas). o Submarine discharge areas – no impact pathways were identified from the onshore components of the Project that could affect the flow and quality of groundwater to shallow submarine discharge areas. The Lower Aquifer System discharges offshore via vertical leakage. The volume of groundwater removed from the Lower Aquifer System due to gas extraction from the Project would be negligible compared to overall Basin wide offshore discharge, and not considered to present a material impact to any potential submarine discharge areas. Section 6.4.1 – GB Energy acknowledges this comment and the ASSMP will be prepared in accordance with MM-CO05 and approved with the CEMP (pursuant to the Pipelines Act) prior to commencement of construction. Section 6.4.2 (Wet Trenching) – CO11: GB Energy will include this recommendation within the ASSMP to be prepared in accordance with MM-CO05 as opposed to a further mitigation measure and another management plan. In respect of the comments regarding the establishment of baseline conditions of surface water and groundwater in the vicinity of wet trenching area, this was discussed through the TRG and addressed in the comment spreadsheets, please refer to MM- SW02 for proposed sampling at trenched watercourse crossings. Section 6.4.2 (Wet Trenching) – Amendment to CO05: GB Energy accepts this recommendation.
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 8
Golden Beach Gas Project
Section 6.4.2 (Wet Trenching) – Further point to CO05: GB Energy accepts this recommendation. Section 6.4.2 (Soil Contamination) – CO01: GB Energy accepts this recommendation. Section 6.4.2 (Soil Contamination) – CO02: GB Energy accepts this recommendation. Section 6.4.2 (Soil Contamination) – CO04: GB Energy accepts this recommendation. Section 6.4.3 – GB Energy accepts this recommendation and will include in MM-CO01. Section 6.4.4 – GB Energy accepts this recommendation. Section 6.6.1 – GB Energy does not accept this recommendation. GB Energy will prepare a plan to manage noise and vibration during construction in consultation with EPA (per MM-NV01). This plan will be incorporated within the CEMP to be approved/accepted under the Pipelines Act. Section 6.6.3 – GB Energy accepts this recommendation.
2.2.4 Submission 6 – Individual submitter, multiple key issues GB Energy acknowledges the matters raised in Submission 6 and responds as follows: Social Impacts, Amenity Impacts, Noise and Lighting GB Energy has consulted extensively with both the local Golden Beach community and affected landowners (including the landowners of the proposed compressor station site) in respect of the Project including the design of key components since October 2018. The final project design has taken into account the feedback over this period from these stakeholders. GB Energy will continue to work with the community and landowners to ensure that their feedback is received and their concerns addressed. GBE should have to submit a plan to manage on-farm issues such as biosecurity, animal welfare and associated risks including stopping works during critical times such as calving, lambing, and foaling. GB Energy will agree a Property Management Plan with each landowner in conjunction with land tenure discussions. This will include the points raised above and any on farm management practices. See MM-SE03 GBE should have to put up an upfront cash bond to ensure compensation is fully-funded and available to aggrieved landowners Please refer to Part 10, Division 1 of the Pipelines Act which sets out the requirements for rehabilitation bonds for pipeline project proponents.
2.2.5 Submission 8 – The CarbonNet Project GB Energy has developed, and continues to have, an excellent collaborative working relationship with CarbonNet. Whilst GB Energy recognises the importance of understanding potential cumulative impacts from other projects or actions that may affect the same environmental assets as the Project, given the current status of the CarbonNet Project (pre-referral and pre-commercialisation), GB Energy acknowledges the position espoused by the Environment Protection Authority in its submission (Submission 5) that it is not appropriate for GB Energy to have regard to the proposed CarbonNet Project when considering impacts. Potential cumulative impacts in relation to groundwater were considered in the EES due to questions raised by the community at an information session. GB Energy will continue to work collaboratively with the CarbonNet Project as an overlapping tenement holder and as CarbonNet defines its onshore infrastructure and locations. GB Energy will continue to liaise with the CarbonNet Project as it identifies preferred onshore alignments to ensure appropriate protections are included in GB Energy’s detailed design to enable potential future co-location or construction in the vicinity of the GB Energy pipeline (and onshore facilities) where feasible.
2.2.6 Submission 9 – DELWP Gippsland Region Adopting the numbering used in Submission 9, GB Energy responds as follows:
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 9
Golden Beach Gas Project
8) Practical Ecology provided the outstanding Vegetation Quality Assessments to DELWP Gippsland Region on 21 December 2020. Any further matters can be addressed in the refined impact assessment pursuant to MM-FF01. 9) Please refer to Targeted Spring Surveys Assessment (Arcadis 2020) available on Engage Victoria website for an updated impact assessment in respect of: o Maroon Leek-orchid Prasophyllum frenchii: EPBC Act Endangered, FFG Act listed, endangered in Victoria o Metallic Sun-orchid Thelymitra epipactoides: EPBC Act Endangered, FFG Act listed, endangered in Victoria o Thick-lip Spider-orchid Caladenia tessellata: EPBC Act Vulnerable, vulnerable in Victoria o Wellington Mint-bush Prostanthera galbraithiae: EPBC Act Vulnerable, FFG Act listed, vulnerable in Victoria o Trailing Hop-bush Dodonaea procumbens: EPBC Act Vulnerable, vulnerable in Victoria o Dwarf Kerrawang Commersonia prostrata: EPBC Act Endangered, FFG Act listed, endangered in Victoria o Gippsland Lakes Peppermint Eucalyptus arenicola: rare in Victoria 11) Paragraph 3: MMFF5 - Reinstatement and revegetation will be undertaken in accordance with FF05, included in the CEMP (and supporting Environmental Line List) and in accordance with the APGA Code of Environmental Practice. Paragraph 5: MMFF15 – Recommendation is noted and accepted. In addition, submitter 10 will participate in the preparation of the precautionary translocation plan (and wider Flora/Orchid Management Plan). Paragraphs 6 and 7: Horizontal Directional Drilling (HDD) versus trenched crossings are considered in Chapter 3 of the EES. Cost amounts have not been included in the EES, but HDD would be 2 - 3 times the cost of trenching (including native vegetation offset considerations). The duration of works in the vicinity of the Lake Reeve Ramsar wetlands would be 22 days rather than 2 – 7 days.
2.2.7 Submission 10 - Australasian Native Orchid Society (Victorian Group) Inc In accordance with the recommendation in Technical Report A Terrestrial and Freshwater Biodiversity (Practical Ecology 2020), GB Energy commissioned Arcadis to undertake additional targeted surveys for the following species listed under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act), as well as species listed under the Victorian Flora and Fauna Guarantee Act 1988 (FFG Act) and Victorian Advisory List (DEPI 2014):
Maroon Leek-orchid Prasophyllum frenchii: EPBC Act Endangered, FFG Act listed, endangered in Victoria Metallic Sun-orchid Thelymitra epipactoides: EPBC Act Endangered, FFG Act listed, endangered in Victoria
Thick-lip Spider-orchid Caladenia tessellata: EPBC Act Vulnerable, vulnerable in Victoria
Wellington Mint-bush Prostanthera galbraithiae: EPBC Act Vulnerable, FFG Act listed, vulnerable in Victoria
Trailing Hop-bush Dodonaea procumbens: EPBC Act Vulnerable, vulnerable in Victoria
Dwarf Kerrawang Commersonia prostrata: EPBC Act Endangered, FFG Act listed, endangered in Victoria Gippsland Lakes Peppermint Eucalyptus arenicola: rare in Victoria
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 10
Golden Beach Gas Project
Arcadis provided its written findings from these targeted surveys to GB Energy on 11 December 2020. A redacted copy of this report is available on the Engage Victoria website.
In summary, no EPBC Act listed species were identified within the Construction Footprint, though some species occur immediately adjoining the construction zone. It is understood that Wellington Mint-bush also occurred along the alignment in one location – these plants have since died however a soil-stored seed bank may be present.
Four species classified as rare in Victoria were recorded:
• Gippsland Lakes Peppermint Eucalyptus arenicola: scattered in several locations • Slender Wire-lily Laxmannia gracilis: one plant located on Sandy Camp Road • Salt Lawrencia Lawrencia spicata: multiple plants located on the edge of Lake Reeve • Ribbed Thryptomene Thryptomene micrantha: multiple plants located west of Lake Reeve.
Mitigation measures to avoid impacts to the EPBC Act listed species will be required, including No Go Zone fencing, reinstatement of habitat and construction personnel inductions. Provided these mitigation measures are followed, the Project is not considered likely to have a significant impact on any rare or threatened flora species.
The redacted version of the Arcadis report was provided via the Engage Victoria website to Mr Garry French on behalf of the Australasian Native Orchid Society (Victorian Group) Inc on 16 December 2020. GB Energy has also had a telephone conversation with Mr French on 23 December 2020 who has requested a copy of the unredacted version to enable him to confirm the locations of the Maroon Leek Orchid and Metallic Sun Orchid. Subject to requisite approval from Arcadis and DELWP, GB Energy will provide this report to Mr French on a confidential basis and subject to him undertaking to us that it will not be provided to any other party. GB Energy and Mr French have agreed to continue to collaborate including with respect to the preparation and implementation of the proposed flora/orchid management plan (to be approved as part of the CEMP pursuant to the Pipelines Act) for the Project.
2.2.8 Submission 11 – Individual submitter, multiple key issues GB Energy acknowledges the matters raised in Submission 11 and responds to the matters in italics as follows: Climate Issues
Actual monitoring of CO2 and methane emissions should be conducted for at least the first year of operation and subsequently if further turbines are installed. Monitoring will be undertaken in accordance with the WAA and the National Greenhouse and Energy Reporting Act 2007. Strong cleanup bonds will need to be part of any conditions if this project goes ahead. Please refer to the Pipelines Act and OPGSS Act which set out the requirements for rehabilitation bonds. Radioactive Waste It is inexcusable to ignore Radiation issues in this EES. The gas within the Golden Beach Gas Field is sweet and dry (94.3% methane, 5.5% Nitrogen & 0.1% CO2) and no liquids are anticipated to be produced apart from entrained water with the gas. Full gas sample composition is provided in the tabled document 11 (Response to Request for Information) and section 4.9 of Attachment 8 (Project Basis of Design) of the Application. The gas sample taken does not provide any evidence to suggest that radioactive substances will be generated.
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 11
Golden Beach Gas Project
Further, utility pigging, for the cleaning and push through of sand and water in the raw gas pipeline, will be undertaken at regular intervals (usually 3 – 6 months), or opportunistically following switch over to injection after extended withdrawal from the reservoir in the storage phase (see section 4.6.4 of Chapter 4, Project Description). The regular pigging of the raw gas pipeline and disposal of produced water (in accordance with MM-CO10) will prevent the accumulation of Technologically Enhanced Naturally Occurring Radioactive Materials (TENORMs) by the Project. Air Quality A condition of any approval for this project must be that they undertake 12 months of baseline monitoring before they start digging. Background monitoring data was adopted from areas which have a greater pollution potential as a function of population and industrial emissions. Whilst this would underpredict the actual scale of cumulative air quality impacts of the Project, it is conservative, and appropriate for the purposes of the EES assessment in demonstrating compliance with regulatory criteria (see Technical Report L – Air Quality). The National Environment Protection (Ambient Air Quality) Measure (AAQ NEPM) was formed in 1998 under the National Environment Protection Council Act 1994 (NEPC Act). It was designed to create a nationally consistent framework for monitoring and reporting on common ambient air pollutants. For the purpose of the operational assessment of the Project’s impact on air quality, pollutants of interest are carbon monoxide (CO), nitrogen dioxide (NO2), sulphur dioxide (SO2) and particulate matter with a diameter less than 10 micrometres (PM10). The AAQ NEPM was varied in 2003 to include particulate matter with a diameter of less than 2.5 micrometres (PM2.5) and is therefore also considered in the Project’s assessment. The information provided only looks at a few potential AQ problems namely NoX, CO, formaldehyde and benzene, which have been handpicked based on US conditions, as likely problems here. The emissions modelling is based on the National Greenhouse Accounts Factors (NGAF) prepared by the Australian Government Department of Environment and Energy, July 2017. Gas from some other wells in Bass Strait contain mercury at significant levels. No data is supplied to evaluate whether this is a problem for this project. The gas sample taken does not provide any evidence to suggest that mercury will be generated. See tabled document 11 (Response to Request for Information) and section 4.9 of Attachment 8 (Project Basis of Design) of the Application for sampled gas composition. Additionally, it mentions dehydration in passing. It is not clear where the water goes as there does not appear to be a pondage at the compressor station (although the quality of the map of the compressor station layout, is so poor as to be virtually unreadable) Process water is mentioned but is only a tank. The EES lists in multiple chapters and technical reports the various components of the compressor station including water/inlet separation and the triethylene glycol (TEG) equipment (see for example Table 4.3 in Chapter 4). The inlet separation at the compressor station would collect the free liquids (i.e. water) from the pipeline and then the TEG equipment is used to dehydrate the gas to ensure the sales gas meets the AEMO gas specification requirements. We also refer the submitter to sections 7.5, 12 and 13 in the WAA for a detailed discussion with respect to the water separation, the dehydration process and the process with respect to water treatment. Gas Quality There is no analysis, that I could find, of the actual gas components, other than hydrocarbons assumed to be almost entirely methane Other wells in the area often have significant levels of CO2 almost to the point of not burning properly in your kitchen. The gas within the Golden Beach Gas Field is sweet and dry (94.3% methane, 5.5% Nitrogen & 0.1% CO2) and no liquids are anticipated to be produced apart from entrained water with the gas. Please refer to section 4.9 of Attachment 8 (Project Basis of Design) of the Application for a detailed breakdown of the gas composition. The gas composition was also provided in tabled document 11 (Response to Request for Information).
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 12
Golden Beach Gas Project
Dutson Downs Issues A thorough biodiversity survey should be conducted ahead of planned excavations and offsets made condition of proceeding. Please refer to Technical Report A (Practical Ecology 2020) which is the detailed impact assessment following 12 months of biodiversity surveys across all four seasons. In addition, we refer you to the Targeted Spring Surveys Assessment Report (Arcadis 2020) which is available on the Engage Victoria website which details the further flora surveys undertaken in October and November 2020. GB Energy will secure all required offsets prior to commencement of construction (and prior to removal of native vegetation).
2.2.9 Submission 12 – Individual submitter, multiple key issues GB Energy acknowledges the matters raised in Submission 12 and responds as follows to those matters in italics: First issue of concern is the non-declaring of potential cumulative impacts from other developments proposed for the same region. Cumulative impacts are discussed in the Project EES and reference is made to Technical Report A (Terrestrial and Freshwater Biodiversity) and Chapter 7, Technical Report B (Marine) and Chapter 8, Technical Report F (Noise and Vibration) and Chapter 12, Technical Report I (Traffic) and Chapter 15 and Technical Report L (Air Quality) and Chapter 18 for further discussion on potential cumulative impacts. In respect of the CarbonNet Project, GB Energy has not considered cumulative impacts on the CarbonNet Project for onshore activities other than groundwater impacts as requested by the community (which has been queried by the EPA as per submission 5). This is due to the CarbonNet Project still being in the pre-approval phase and with no defined pipeline alignment. GB Energy seeks to avoid and minimise its impacts in accordance with Native Vegetation removal principles. GB Energy will continue to work collaboratively with the CarbonNet Project as an overlapping tenement holder and as it defines its onshore infrastructure and locations. GB Energy will continue to liaise with the CarbonNet Project as it identifies preferred onshore alignments to ensure appropriate protections (where feasible) are included in GB Energy’s detailed design to enable potential future co-location or construction in the vicinity of the GB Energy pipeline (and onshore facilities). Second Issue of concern is the hydrology and hydrogeology impacts during operation phases.
See Technical Report G – Groundwater. Potential reductions in groundwater pressures and additional land subsidence due to the Project were compared to existing conditions, which include historical changes that have occurred. The possible increased sensitivity of the groundwater system to historical impacts was therefore implicitly considered. Overall, the additional impact from the Project on groundwater pressures (Section 8.2.2 of Technical Report G) and subsidence (Section 8.2.3 of Technical Report G) were assessed as minor; with the recommendation for GB Energy to participate in future regional data assessments conducted by regulators and stakeholders to further current understanding of the combined regional impacts (Section 10.2 of Technical Report G). Third issue of concern with breaching of the outer dune barrier dune The operational risk of contribution to subsidence (and potential compromise of the outer dune barrier) was considered as part of the EES with a risk rating of very low (see Risk GW08, Table 7- 1, Technical Report G). Subsidence is further considered as an operational impact (see Section 8.2 of Technical Report G), and the potential for subsidence as a result of this Project is considered low given the size and timescale of potential additional reductions to onshore groundwater levels in the Lower Tertiary
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 13
Golden Beach Gas Project
Aquifer (as described earlier in Section 7.0, Technical Report G). In particular, groundwater levels in the Lower Tertiary Aquifer are estimated to decline and substantially recover within ten years of initial production and final production operations commencing. The relatively short-term decline and then subsequent recovery of groundwater levels would limit the vertical propagation of pressure reduction, and therefore affect less of the compressible material within the Lower Tertiary Aquifer System and overlying formations. Any cumulative compaction of compressible sediments would therefore be small relative to those induced by the long-term and substantial pressure declines that have already occurred. No significant adverse effects on groundwater are anticipated, and the potential impacts to groundwater from additional subsidence due to the Project are assessed as minor. Fourth issue of concern is contamination of soils Acid sulfate soils (known locations and unexpected intersects) will be managed in accordance with the approved ASSMP (see MM-CO05). Any further testing required to inform the ASSMP will be undertaken in development of the ASSMP. Based on sampling undertaken as part of the EES, the concentrations of PFOS and PFOA are below the adjusted interim criteria for reuse of PFAS impacted soil as prescribed by the EPA Victoria Publication 1669.3: Interim position statement on PFAS and can be reused on site. Further, GB Energy will include recommendations of the EPA per submission 5 in relation to PFAS in MM-CO01 and the CEMP to be approved under the Pipelines Act (see section 6.4.3, Submission 5).
2.2.10 Submission 13 – West Gippsland Catchment Management Authority GB Energy acknowledges Submission 13. The West Gippsland Catchment Management Authority has participated in the Project’s EES TRG and GB Energy notes that the matters raised in Submission 13 have been addressed in the EES and require no further response.
3. Conclusion GB Energy appreciates the contributions of each of the submitters referred to above and thanks each of them for their interest in the Project and the EES.
GB Energy notes no submissions were received from affected landowners or occupiers of the land subject to the Application exhibited with the EES (other than Wellington Shire Council in its capacity as local council and not as a landowner) or from the local Golden Beach community. GB Energy has worked extensively with landowners and the local Golden Beach community to provide comprehensive and transparent information in relation to the Project, the EES process and the Application.
GB Energy has considered each of the issues raised in the submissions and believes we can adequately address submissions received through the public exhibition period as set out in this response.
N/A | Response to submissions received on the Project EES– Environment Effects Act 1978 14