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– Wednesday, 08 July 2020 – 15:32:00 Subject DENR - Consultation Form - 904190 From Sent 7/8/2020 3:32:00 PM Contact details First name: Shirley Surname: Crane Email address: ************* Country: Australia Postcode: 0850 Phone number: ********* Stakeholder type: Community Feedback Activity you are providing feedback on: Imperial Oil and Gas Pty Ltd (IMP2-5): 2020 Drilling Program NT Exploration Permit (EP) 187 Revised Environment Management Plan Category type: Water If other, please specify:: Comments: When the current NTGovernment lifted the moratorium on fracking, the public was assured that there would be no wet season operations, in line with the Pepper Scientific Recommendations that declared wet season operations unsafe. The risk of environmental damage and water contamination is much higher in the wet season. It seems that the gas companies are eroding the recommendations one by one and are basically setting themselves up to do as they please. The 135 recommendations seem to have ‘gone out the window’ and the NT Government is doing very little to enforce them. Initially, we were assured that all 135 recommendations would be implemented before one well was drilled. We now know that the recommendations have been divided into groups - ones that are part of the exploration phase (which turned out to be a very small number), ones that seem to apply only to the production phase, ones that can’t be implemented and, therefore, will just be forgotten about and ones that no one takes any notice of. There is little evidence that the NT Government has the capacity to adequately monitor what is going on, so the gas companies have little to concern themselves with - the NT Government just seems to ‘adjust’ the circumstances to suit the gas companies and that absolves them of any responsibility for enforcing particular recommendations. Allowing wet season operations is a totally unsatisfactory response and is a very clear indicator that the recommendations aren’t worth the paper they’re printed on. Attachment: No file uploaded Attachment 2: No file uploaded Attachment 3: No file uploaded Attachment 4: No file uploaded Attachment 5: No file uploaded Privacy: Page 1 of 1149

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Page 1: Wednesday, 08 July 2020 – 15:32:00

– Wednesday, 08 July 2020 – 15:32:00Subject DENR - Consultation Form - 904190FromSent 7/8/2020 3:32:00 PM

Contact detailsFirst name: ShirleySurname: CraneEmail address: *************Country: AustraliaPostcode: 0850Phone number: *********Stakeholder type: CommunityFeedbackActivity you are providing feedback on: Imperial Oil and Gas Pty Ltd (IMP2-5): 2020Drilling Program NT Exploration Permit (EP) 187 Revised Environment Management Plan

Category type: WaterIf other, please specify::Comments: When the current NTGovernment lifted the moratorium on fracking, the publicwas assured that there would be no wet season operations, in line with the Pepper ScientificRecommendations that declared wet season operations unsafe. The risk of environmentaldamage and water contamination is much higher in the wet season. It seems that the gascompanies are eroding the recommendations one by one and are basically setting themselvesup to do as they please. The 135 recommendations seem to have ‘gone out the window’ andthe NT Government is doing very little to enforce them. Initially, we were assured that all 135recommendations would be implemented before one well was drilled. We now know that therecommendations have been divided into groups - ones that are part of the exploration phase(which turned out to be a very small number), ones that seem to apply only to the productionphase, ones that can’t be implemented and, therefore, will just be forgotten about and onesthat no one takes any notice of. There is little evidence that the NT Government has thecapacity to adequately monitor what is going on, so the gas companies have little to concernthemselves with - the NT Government just seems to ‘adjust’ the circumstances to suit the gascompanies and that absolves them of any responsibility for enforcing particularrecommendations. Allowing wet season operations is a totally unsatisfactory response and is avery clear indicator that the recommendations aren’t worth the paper they’re printed on.

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– Saturday, 18 July 2020 – 11:13:07Subject Objection to Imperial Oil and Gas wet season drilling EP187FromSent 7/18/2020 11:13:07 AM

Dear Sir/Madam

With the price of fossil fuels free falling, it might be worthwhile divesting from fossil fuelsand rehabilitating your investments to ensure future income and growth.The answer may be in creating jobs in the community, through easy access education andlocal learning opportunities. If the government invested in local projects. resourcing (rubbishas a resource), microfactories using 3D printers, food and energy creation. The outcomes foryouth who have slipped through the cracks of the education system would be a lot better.I am hoping that winding down fossil fuels and investing in jobs in the local areas and forAustralian farming and mining companies by creating food, energy and micro industry in thelocal community forms part of government plans. If it doesn't here is some action we cantake;

Taking a few minutes to find your local MPs email and copy and paste. A follow up phonecall will make the office junior take note. Getting neighbours, friends and family to do thesame will mean they will have to change their ways or we can oust them for not followingdirections.We just need to take a few minutes to let them know how we would like to be represented.I am praying for a miracle, complacency is our enemy.Dear Honorable Members of Parliament,

I hope you will have a look at some of these ideas and seriously consider investing taxpayerfunded resources and dollars into supporting Australian owned farms, mines and local areasinto planting industrial hemp and developing a plant to product processing (biofuel, 3DFilament and 3D printer (microfactory) mirreco houses).

Given that we are one of the sunniest places on the planet, we now have an unprecedentedopportunity to take advantage of this free natural resource. All it takes us a change in mindsetand valuing what matters most Clean air, water and environment. These are essential to oursurvival and our current energy choices are not reflecting their importance.

If investors changed direction and government provided resources (defence forces, experts inthe field under employed) to introduce sustainable energy sources Biodigestors, composters,solar and wind generators. and water efficient practices to Australian owned farms and miningoperations and suburban areas. It would help people in all areas get back on their feet andreduce operating expenses.

Our current agricultural practices could do with a rethink. Industrial Hemp is a truly versatiletextile which has been used to produce and fuel an airplane stronger then steel, build houses,paper, clothes, 3D filament, a superconductor better than graphene and the seed is highlynutritious. 5 to 10 Macadamia nuts a day are good for the heart. Chia and linseed are proteinand nutrient rich.Using regenerative farming practices reduces, water, fertilizer and pest control expense. Weshould be supplying our defence force and under employed resources to Australian ownedfarmers and mining operations to help them to change to regenerative farming practices andencouraging nutrient dense, water efficient multifunction plants (eg Hemp over cotton,

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maccas over almonds, chia and linseed over rice). Our defence force should be assisting indefence of our food.

Netherlands is the second biggest exporter of food in the world after the US , even thoughtthey are one if the smallest nations. This is because the grow everything in green houseswhich conserve nutrients, water and reduce pests. Solar poweredHydroponic, aquaponic, vertical superfood production systems should be provided by thegovernment to all Australian owned farm, mining operations and in suburbs. This is where Iwant my taxpayer dollars to go, what about you?Check out The BZE million jobs plan launched on Monday (same day one of the largestfrackers in the US filed for bankruptcy).https://bze.org.au/the-million-jobs-plan/

Thank you for considering actions for a better futureBest regardsMargaret King*********

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– Monday, 20 July 2020 – 11:37:13Subject DENR - Consultation Form - 908332FromSent 7/20/2020 11:37:13 AM

Contact detailsFirst name: PeterSurname: RobertsonEmail address: *************Country: AustraliaPostcode: 0820Phone number: *********Stakeholder type: CommunityFeedbackActivity you are providing feedback on: Imperial Oil and Gas Pty Ltd (IMP2-5): 2020Drilling Program NT Exploration Permit (EP) 187 Revised Environment Management Plan

Category type: Social and cultural, Flora and fauna, Water, Waste Management,Climate change, Human health, Chemicals, Regulation and compliance, Well integrity

If other, please specify:: No economic case to develop onshore unconventional gasindustry in NT as it will only operate with huge government (public) subsidies and byexternalising environmental and impacts and costs.Comments: The proposal should not be approved because of the following factors: Socialand cultural As the Pepper Inquiry stated, there is no social license for fracking in the NT.Flora and fauna Flora and fauna will be adversely impacted through clearing, pollution of airand waterways, noise, and road kill from increased vehicle movements. Water The companycannot guarantee that surface and groundwater will not be polluted by the proposal, both inthe short and the long term. Waste Management It is unacceptable to allow open storage ofpolluted waste water. Climate change The fracking industry consistently and deliberatelyunderstates the level of fugitive methane emissions it is responsible for. Methane is a farworse GHG than CO2 and under no circumstances should its release be approved. Humanhealth Communities around the proposal will be affected adversely in a range of waysincluding increased heavy vehicle movements, noise, air and water pollution, industryemployees moving into communities. Chemicals Fracking introduces a range of toxic anduntested, potentially toxic chemicals into otherwise uncontaminated water systems. This isnot acceptable. Regulation and compliance The recommendations of the Pepper Inquiry haveNOT been implemented, e.g. full cost recovery. Well integrity There is no way companieswill be held accountable for decades to come for the wells they frack and then abandon. Thesewells have the potential to contaminate air, land and water systems for decades.

Attachment: TAI_P510-Cooked-with-gas-Darwin-days-over-35C-FINAL.pdf, typeapplication/pdf, 621.6 KBAttachment 2: TAI_P875-All-its-Fracked-Up-to-Be-WEB.pdf, type application/pdf, 282.5 KB

Attachment 3: Fracking_Methane_latest-US-data-on-fugitive-emissions.pdf, typeapplication/pdf, 211.7 KBAttachment 4: No file uploadedAttachment 5: No file uploadedPrivacy:

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Attached Documents

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GREENHOUSE GASES

Assessment of methane emissionsfrom the U.S. oil and gas supply chainRamón A. Alvarez1*, Daniel Zavala-Araiza1, David R. Lyon1, David T. Allen2,Zachary R. Barkley3, Adam R. Brandt4, Kenneth J. Davis3, Scott C. Herndon5,Daniel J. Jacob6, Anna Karion7, Eric A. Kort8, Brian K. Lamb9, Thomas Lauvaux3,Joannes D. Maasakkers6, Anthony J. Marchese10, Mark Omara1, Stephen W. Pacala11,Jeff Peischl12,13, Allen L. Robinson14, Paul B. Shepson15, Colm Sweeney13,Amy Townsend-Small16, Steven C. Wofsy6, Steven P. Hamburg1

Methane emissions from the U.S. oil and natural gas supply chain were estimated byusing ground-based, facility-scale measurements and validated with aircraft observationsin areas accounting for ~30% of U.S. gas production. When scaled up nationally, ourfacility-based estimate of 2015 supply chain emissions is 13 ± 2 teragrams per year,equivalent to 2.3% of gross U.S. gas production. This value is ~60% higher than the U.S.Environmental Protection Agency inventory estimate, likely because existing inventorymethods miss emissions released during abnormal operating conditions. Methaneemissions of this magnitude, per unit of natural gas consumed, produce radiative forcingover a 20-year time horizon comparable to the CO2 from natural gas combustion.Substantial emission reductions are feasible through rapid detection of the root causesof high emissions and deployment of less failure-prone systems.

Methane (CH4) is a potent greenhouse gas,and CH4 emissions from human activitiessince preindustrial times are responsi-ble for 0.97 W m−2 of radiative forcing,as compared to 1.7 W m−2 for carbon

dioxide (CO2) (1). CH4 is removed from the at-mosphere much more rapidly than CO2; thus,reducing CH4 emissions can effectively reducethe near-term rate of warming (2). Sharp growthin U.S. oil and natural gas (O/NG) productionbeginning around 2005 (3) raised concerns aboutthe climate impacts of increased natural gas use(4, 5). By 2012, disagreement among publishedestimates of CH4 emissions from U.S. naturalgas operations led to a broad consensus thatadditional data were needed to better charac-terize emission rates (4–7). A large body of fieldmeasurements made between 2012 and 2016(table S1) has markedly improved understandingof the sources and magnitude of CH4 emissionsfrom the industry’s operations. Brandt et al. sum-marized the early literature (8); other assessmentsincorporated elements of recent data (9–11). Thiswork synthesizes recent studies to provide animproved overall assessment of emissions from

the O/NG supply chain, which we define to in-clude all operations associated with O/NG pro-duction, processing, and transport (materials andmethods, section S1.0) (12).Measurements of O/NG CH4 emissions can

be classified as either top-down (TD) or bottom-up (BU). TD studies quantify ambient methaneenhancements using aircraft, satellites, or towernetworks and infer aggregate emissions from allcontributing sources across large geographies.TD estimates for nine O/NG production areashave been reported to date (table S2). Theseareas are distributed across the U.S. (fig. S1)and account for ~33% of natural gas, ~24% of oilproduction, and ~14% of all wells (13). Areassampled in TD studies also span the range ofhydrocarbon characteristics (predominantly gas,predominantly oil, or mixed), as well as a range ofproduction characteristics such as well produc-tivity and maturity. In contrast, BU studies gener-ate regional, state, or national emission estimatesby aggregating and extrapolatingmeasured emis-sions from individual pieces of equipment, oper-ations, or facilities, using measurements madedirectly at the emission point or, in the case offacilities, directly downwind.Recent BU studies have been performed on

equipment or facilities that are expected to rep-resent the vast majority of emissions from theO/NG supply chain (table S1). In this work, weintegrate the results of recent facility-scale BUstudies to estimate CH4 emissions from the U.S.O/NG supply chain, and then we validate theresults using TD studies (materials and meth-ods). The probability distributions of our BUmethodology are based on observed facility-level emissions, in contrast to the component-by-component approach used for conventionalinventories. We thus capture enhancements pro-

duced by all sources within a facility, includingthe heavy tail of the distribution. When the BUestimate is developed in this manner, directcomparison of BU and TD estimates of CH4

emissions in the nine basins for which TDmeasurements have been reported indicatesagreement betweenmethods, within estimateduncertainty ranges (Fig. 1).Our national BU estimate of total CH4 emis-

sions in 2015 from the U.S. O/NG supply chainis 13 (+2.1/−1.6, 95% confidence interval) TgCH4/year (Table 1). This estimate of O/NG CH4

emissions can also be expressed as a production-normalized emission rate of 2.3% (+0.4%/−0.3%)by normalizing by annual gross natural gas pro-duction [33 trillion cubic feet (13), with averageCH4 content of 90 volume %]. Roughly 85% ofnational BU emissions are from production,gathering, and processing sources, which areconcentrated in active O/NG production areas.Our assessment does not update emissions

from local distribution and end use of naturalgas, owing to insufficient information address-ing this portion of the supply chain. However,recent studies suggest that local distributionemissions exceed the current inventory estimate(14–16), and that end-user emissions might alsobe important. If these findings prove to be repre-sentative, overall emissions from the natural gassupply chain would increase relative to the valuein Table 1 (materials and methods, section S1.5).Our BU method and TD measurements yield

similar estimates of U.S. O/NG CH4 emissionsin 2015, and both are significantly higher thanthe corresponding estimate in the U.S. Environ-mental Protection Agency’s Greenhouse GasInventory (EPA GHGI) (Table 1 and materialsand methods, section S1.3) (17). Discrepanciesbetween TD estimates and the EPA GHGI havebeen reported previously (8, 18). Our BU esti-mate is 63% higher than the EPA GHGI, largelydue to a more than twofold difference in theproduction segment (Table 1). The discrepancyin production sector emissions alone is ~4 TgCH4/year, an amount larger than the emissionsfrom any other O/NG supply chain segment.Such a large difference cannot be attributed toexpected uncertainty in either estimate: Theextremal ends of the 95% confidence intervalsfor each estimate differ by 20% (i.e., ~12 Tg/yearfor the lower bound of our BU estimate can becompared to ~10 Tg/year for the upper boundof the EPA GHGI estimate).We believe the reason for such large divergence

is that sampling methods underlying conven-tional inventories systematically underestimatetotal emissions because they miss high emis-sions caused by abnormal operating conditions(e.g., malfunctions). Distributions of measuredemissions from production sites in BU studiesare invariably “tail-heavy,” with large emissionrates measured at a small subset of sites at anysingle point in time (19–22). Consequently, themost likely hypothesis for the difference be-tween the EPA GHGI and BU estimates derivedfrom facility-level measurements is that measure-ments used to develop GHGI emission factors

RESEARCH

Alvarez et al., Science 361, 186–188 (2018) 13 July 2018 1 of 3

1Environmental Defense Fund, Austin, TX, USA. 2Universityof Texas at Austin, Austin, TX, USA. 3The PennsylvaniaState University, University Park, PA, USA. 4StanfordUniversity, Stanford, CA, USA. 5Aerodyne Research Inc.,Billerica, MA, USA. 6Harvard University, Cambridge, MA,USA. 7National Institute of Standards and Technology,Gaithersburg, MD, USA. 8University of Michigan, AnnArbor, MI, USA. 9Washington State University, Pullman,WA, USA. 10Colorado State University, Fort Collins, CO,USA. 11Princeton University, Princeton, NJ, USA.12University of Colorado, CIRES, Boulder, CO, USA. 13NOAAEarth System Research Laboratory, Boulder, CO, USA.14Carnegie Mellon University, Pittsburgh, PA, USA.15Purdue University, West Lafayette, IN, USA. 16Universityof Cincinnati, Cincinnati, OH, USA.*Corresponding author. Email: [email protected]

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undersample abnormal operating conditionsencountered during the BU work. Component-based inventory estimates like the GHGI havebeen shown to underestimate facility-level emis-sions (23), probably because of the technicaldifficulty and safety and liability risks asso-ciated with measuring large emissions from, forexample, venting tanks such as those observedin aerial surveys (24).Abnormal conditions causing high CH4 emis-

sions have been observed in studies across theO/NG supply chain. An analysis of site-scale emis-sion measurements in the Barnett Shale con-cluded that equipment behaving as designedcould not explain the number of high-emittingproduction sites in the region (23). An extensiveaerial infrared camera survey of ~8000 pro-duction sites in seven U.S. O/NG basins foundthat ~4% of surveyed sites had one or moreobservable high–emission rate plumes (24) (de-tection threshold of ~3 to 10 kg CH4/hour wastwo to seven times higher than mean produc-tion site emissions estimated in this work). Emis-sions released from liquid storage tank hatchesand vents represented 90% of these sightings.It appears that abnormal operating conditionsmust be largely responsible, because the obser-vation frequency was too high to be attributedto routine operations like condensate flashingor liquid unloadings alone (24). All other ob-servations were due to anomalous venting fromdehydrators, separators, and flares. Notably, thetwo largest sources of aggregate emissions in theEPA GHGI—pneumatic controllers and equip-ment leaks—were never observed from theseaerial surveys. Similarly, a national survey ofgathering facilities found that emission rateswere four times higher at the 20% of facilitieswhere substantial tank venting emissions wereobserved, as compared to the 80% of facilitieswithout such venting (25). In addition, very largeemissions from leaking isolation valves at trans-mission and storage facilities were quantified bymeans of downwind measurement but could notbe accurately (or safely) measured by on-sitemethods (26). There is an urgent need to com-plete equipment-based measurement campaignsthat capture these large-emission events, so thattheir causes are better understood.In contrast to abnormal operational condi-

tions, alternative explanations such as outdatedcomponent emission factors are unlikely to ex-plain the magnitude of the difference betweenour facility-based BU estimate and the GHGI.First, an equipment-level inventory analogousto the EPA GHGI but updated with recent di-rect measurements of component emissions (ma-terials and methods, section S1.4) predicts totalproduction emissions that are within ~10% ofthe EPA GHGI, although the contributions ofindividual source categories differ significant-ly (table S3). Second, we consider unlikely analternative hypothesis that systematically higheremissions during daytime sampling cause ahigh bias in TD methods (materials and meth-ods, section S1.6). Two other factors may leadto low bias in EPA GHGI and similar inventory

estimates. Operator cooperation is required toobtain site access for emission measurements(8). Operators with lower-emitting sites are plau-sibly more likely to cooperate in such studies,and workers are likely to be more careful toavoid errors or fix problems when measure-ment teams are on site or about to arrive. Thepotential bias due to this “opt-in” study designis very challenging to determine. We thereforerely primarily on site-level, downwind mea-surement methods with limited or no opera-tor forewarning to construct our BU estimate.Another possible source of bias is measurementerror. It has been suggested that malfunction ofa measurement instrument widely used in theO/NG industry contributes to underestimatedemissions in inventories (27); however, this can-not explain the more than twofold difference inproduction emissions (28).

The tail-heavy distribution for many O/NGCH4 emission sources has important implica-tions for mitigation because it suggests thatmost sources—whether they represent wholefacilities or individual pieces of equipment—can have lower emissions when they operate asdesigned. We anticipate that significant emis-sions reductions could be achieved by deployingwell-designed emission detection and repair sys-tems that are capable of identifying abnormallyoperating facilities or equipment. For example,pneumatic controllers and equipment leaks arethe largest emission sources in the O/NG pro-duction segment exclusive of missing emissionsources (38 and 21%, respectively; table S3), withmalfunctioning controllers contributing 66% oftotal pneumatic controller emissions (materialsand methods, section S1.4) and equipment leaks60% higher than the GHGI estimate.

Alvarez et al., Science 361, 186–188 (2018) 13 July 2018 2 of 3

Haynesville (7.7 bcf/d)

Barnett (5.9 bcf/d)

Northeast PA (5.8 bcf/d)

San Juan (2.8 bcf/d)

Fayetteville (2.5 bcf/d)

Bakken (1.9 bcf/d)

Uinta (1.2 bcf/d)

Weld County (1.0 bcf/d)

West Arkoma (0.37 bcf/d)

9-basin sum

A B0.0125

0.0100

0.0075

0.0050

0.0025

9-basin sum, O/NG emissions (Mg CH4/h)D

ensi

ty

Bottom-up

Top-down

0 200 400 600-100% -50% 0% 50% 100% 150%(TD-BU)/TD

Fig. 1. Comparison of this work’s bottom-up (BU) estimates of methane emissions from oiland natural gas (O/NG) sources to top-down (TD) estimates in nine U.S. O/NG production areas.(A) Relative differences of the TD and BU mean emissions, normalized by the TD value, rank orderedby natural gas production in billion cubic feet per day (bcf/d, where 1 bcf = 2.8 × 107 m3). Errorbars represent 95% confidence intervals. (B) Distributions of the nine-basin sum of TD and BU meanestimates (blue and orange probability density, respectively). Neither the ensemble of TD-BU pairs(A) nor the nine-basin sum of means (B) are statistically different [p = 0.13 by a randomization test,and mean difference of 11% (95% confidence interval of −17 to 41%)].

Table 1. Summary of this work’s bottom-up estimates of CH4 emissions from the U.S. oil andnatural gas (O/NG) supply chain (95% confidence interval) and comparison to the EPAGreenhouse Gas Inventory (GHGI).

Industry segment2015 CH4 emissions (Tg/year)

This work (bottom-up) EPA GHGI (17)

Production 7.6 (+1.9/−1.6) 3.5. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .

Gathering 2.6 (+0.59/−0.18) 2.3. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .

Processing 0.72 (+0.20/−0.071) 0.44. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .

Transmission and storage 1.8 (+0.35/−0.22) 1.4. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .

Local distribution* 0.44 (+0.51/−0.22) 0.44. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .

Oil refining and transportation* 0.034 (+0.050/−0.008) 0.034. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .

U.S. O/NG total 13 (+2.1/−1.7) 8.1 (+2.1/−1.4)†. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... .. ... ... .. ... ... .. ... ... .. ... .. ... ... .

*This work’s emission estimates for these sources are taken directly from the GHGI. The local distributionestimate is expected to be a lower bound on actual emissions and does not include losses downstream ofcustomer meters due to leaks or incomplete combustion (materials and methods, section S1.5).†The GHGI only reports industry-wide uncertainties.

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Gathering operations, which transport unpro-cessed natural gas from production sites to pro-cessing plants or transmission pipelines, produce~20% of total O/NG supply chain CH4 emissions.Until the publication of recent measurements(29), these emissions were largely unaccountedby the EPA GHGI. Gas processing, transmissionand storage together contribute another ~20%of total O/NG supply chain emissions, most ofwhich come from ~2500 processing and com-pression facilities.Our estimate of emissions from the U.S. O/NG

supply chain (13 Tg CH4/year) compares to theEPA estimate of 18 Tg CH4/year for all otheranthropogenic CH4 sources (17). Natural gaslosses are a waste of a limited natural resource(~$2 billion/year), increase global levels of sur-face ozone pollution (30), and substantially erodethe potential climate benefits of natural gas use.Indeed, our estimate of CH4 emissions acrossthe supply chain, per unit of gas consumed, re-sults in roughly the same radiative forcing asdoes the CO2 from combustion of natural gasover a 20-year time horizon (31% over 100 years).Moreover, the climate impact of 13 Tg CH4/yearover a 20-year time horizon roughly equals thatfrom the annual CO2 emissions from all U.S. coal-fired power plants operating in 2015 (31% of theimpact over a 100-year time horizon) (materialsand methods, section S1.7).We suggest that inventory methods would be

improved by including the substantial volumeof missing O/NG CH4 emissions evident fromthe large body of scientific work now availableand synthesized here. Such empirical adjustmentsbased on observed data have been previously usedin air quality management (31).The large spatial and temporal variability in

CH4 emissions for similar equipment and fa-cilities (due to equipment malfunction and otherabnormal operating conditions) reinforces theconclusion that substantial emission reductionsare feasible. Key aspects of effective mitigationinclude pairing well-established technologiesand best practices for routine emission sourceswith economically viable systems to rapidly de-tect the root causes of high emissions arisingfrom abnormal conditions. The latter could in-volve combinations of current technologies suchas on-site leak surveys by company personnelusing optical gas imaging (32), deployment ofpassive sensors at individual facilities (33, 34)or mounted on ground-based work trucks (35),and in situ remote-sensing approaches using

tower networks, aircraft, or satellites (36). Overtime, the development of less failure-prone sys-tems would be expected through repeated ob-servation of and further research into commoncauses of abnormal emissions, followed by re-engineered design of individual componentsand processes.

REFERENCES AND NOTES

1. G. Myhre et al., in Climate Change 2013: The Physical ScienceBasis. Contribution of Working Group I to the Fifth AssessmentReport of the Intergovernmental Panel on Climate Change(Cambridge Univ. Press, Cambridge, UK, 2013); www.ipcc.ch/pdf/assessment-report/ar5/wg1/WG1AR5_Chapter08_FINAL.pdf.

2. J. K. Shoemaker, D. P. Schrag, M. J. Molina, V. Ramanathan,Science 342, 1323–1324 (2013).

3. U.S. Energy Information Administration (EIA), “Annual EnergyOutlook 2017” (EIA, 2017); www.eia.gov/outlooks/aeo/.

4. R. W. Howarth, R. Santoro, A. Ingraffea, Clim. Change 106,679–690 (2011).

5. R. A. Alvarez, S. W. Pacala, J. J. Winebrake, W. L. Chameides,S. P. Hamburg, Proc. Natl. Acad. Sci. U.S.A. 109, 6435–6440(2012).

6. U.S. Department of Energy (DOE), “Ninety-day report of theSecretary of Energy Advisory Board’s Shale Gas Subcommittee”(2011); https://energy.gov/downloads/90-day-interim-report-shale-gas-production-secretary-energy-advisory-board.

7. National Petroleum Council (NPC), “Prudent Development:Realizing the Potential of North America’s Abundant NaturalGas and Oil Resources” (NPC, 2011); www.npc.org.

8. A. R. Brandt et al., Science 343, 733–735 (2014).9. D. T. Allen, J. Air Waste Manag. Assoc. 66, 549–575

(2016).10. P. Balcombe, K. Anderson, J. Speirs, N. Brandon, A. Hawkes,

ACS Sustain. Chem.& Eng. 5, 3–20 (2017).11. J. A. Littlefield, J. Marriott, G. A. Schivley, T. J. Skone,

J. Clean. Prod. 148, 118–126 (2017).12. See supplementary materials.13. Drillinginfo, Inc., Drillinginfo Production Query (2015);

https://info.drillinginfo.com/.14. K. McKain et al., Proc. Natl. Acad. Sci. U.S.A. 112, 1941–1946

(2015).15. B. K. Lamb et al., Environ. Sci. Technol. 50, 8910–8917

(2016).16. D. Wunch et al., Atmos. Chem. Phys. 16, 14091–14105 (2016).17. U.S. Environmental Protection Agency (EPA), “Inventory of U.S.

Greenhouse Gas Emissions and Sinks: 1990-2015” (EPA,2017); www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2015.

18. D. Zavala-Araiza et al., Proc. Natl. Acad. Sci. U.S.A. 112,15597–15602 (2015).

19. C. W. Rella, T. R. Tsai, C. G. Botkin, E. R. Crosson, D. Steele,Environ. Sci. Technol. 49, 4742–4748 (2015).

20. M. Omara et al., Environ. Sci. Technol. 50, 2099–2107 (2016).21. A. M. Robertson et al., Environ. Sci. Technol. 51, 8832–8840

(2017).22. A. R. Brandt, G. A. Heath, D. Cooley, Environ. Sci. Technol. 50,

12512–12520 (2016).23. D. Zavala-Araiza et al., Nat. Commun. 8, 14012 (2017).24. D. R. Lyon et al., Environ. Sci. Technol. 50, 4877–4886 (2016).25. A. L. Mitchell et al., Environ. Sci. Technol. 49, 3219–3227 (2015).26. D. J. Zimmerle et al., Environ. Sci. Technol. 49, 9374–9383

(2015).27. T. Howard, T. W. Ferrara, A. Townsend-Small, J. Air Waste

Manag. Assoc. 65, 856–862 (2015).

28. R. A. Alvarez, D. R. Lyon, A. J. Marchese, A. L. Robinson,S. P. Hamburg, Elem. Sci. Anth. 4, 000137 (2016).

29. A. J. Marchese et al., Environ. Sci. Technol. 49, 10718–10727(2015).

30. A. M. Fiore et al., Geophys. Res. Lett. 29, 21-1–25-4(2002).

31. Texas Commission on Environmental Quality (TCEQ), “Houston-Galveston-Brazoria Attainment Demonstration StateImplementation Plan Revision for the 1997 Eight-Hour OzoneStandard” (2010), pp. 3–18; www.tceq.texas.gov/assets/public/implementation/air/sip/hgb/hgb_sip_2009/09017SIP_completeNarr_ado.pdf.

32. A. P. Ravikumar, J. Wang, A. R. Brandt, Environ. Sci. Technol.51, 718–724 (2017).

33. U.S. Department of Energy (DOE) Advanced Research ProjectsAgency – Energy, (ARPA-E, 2014), “ARPA-E MONITOR Program”(ARPA-E); https://arpa-e.energy.gov/?q=programs/monitor.

34. Environmental Defense Fund (EDF), “Methane DetectorsChallenge” (EDF, 2014); www.edf.org/energy/natural-gas-policy/methane-detectors-challenge.

35. J. D. Albertson et al., Environ. Sci. Technol. 50, 2487–2497(2016).

36. D. J. Jacob et al., Atmos. Chem. Phys. 16, 14371–14396(2016).

ACKNOWLEDGMENTS

The authors are grateful to R. Harriss for support in the design andconduct of studies. We thank D. Zimmerle, A. Robertson, andA. Pintar for helpful discussions, and the scores of researchersthat contributed to the body of work assessed here. Funding:Alfred P. Sloan Foundation, Fiona and Stan Druckenmiller,Heising-Simons Foundation, Bill and Susan Oberndorf, Betsy andSam Reeves, Robertson Foundation, TomKat Charitable Trust,and the Walton Family Foundation (for EDF authors as well assupport of related studies involving D.T.A, S.C.H., A.K., E.A.K.,B.K.L., A.J.M., A.L.R., P.B.S., C.S., A.T.-S., S.C.W.); DOE NationalEnergy Technology Laboratory (Z.R.B., K.J.D., T.L., A.L.R.);NASA Earth Science Division (D.J.J., E.A.K., J.D.M.); NOAA ClimateProgram Office (E.A.K., J.P., A.L.R., C.S.). Author contributions:R.A.A., D.Z-A., D.R.L., and S.P.H. conceived the study; R.A.A.,D.Z-A., D.R.L., E.A.K., S.W.P. and S.P.H. designed the study andinterpreted results with input from all authors; each authorcontributed to the collection, analysis, or assessment of oneor more datasets necessary to perform this study; D.Z-A,D.R.L, and S.W.P, performed the analysis, with contributionsfrom R.A.A., A.R.B., A.K., and M.O.; R.A.A., D.Z-A., D.R.L., S.W.P.,S.C.W., and S.P.H. wrote the manuscript with input from allauthors. Competing interests: None declared. Data andmaterials availability: All data and methods needed toreproduce the results in the paper are provided in the paper oras supplementary materials. Additional author disclosures(affiliations, funding sources, financial holdings) are provided inthe supplementary materials.

SUPPLEMENTARY MATERIALS

www.sciencemag.org/content/361/6398/186/suppl/DC1Materials and MethodsAdditional Author DisclosuresFigs. S1 to S11Tables S1 to S12References (37–77)Databases S1 and S2

19 December 2017; accepted 18 May 2018Published online 21 June 201810.1126/science.aar7204

Alvarez et al., Science 361, 186–188 (2018) 13 July 2018 3 of 3

RESEARCH | REPORTon July 19, 2020

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Assessment of methane emissions from the U.S. oil and gas supply chain

Sweeney, Amy Townsend-Small, Steven C. Wofsy and Steven P. HamburgMaasakkers, Anthony J. Marchese, Mark Omara, Stephen W. Pacala, Jeff Peischl, Allen L. Robinson, Paul B. Shepson, ColmDavis, Scott C. Herndon, Daniel J. Jacob, Anna Karion, Eric A. Kort, Brian K. Lamb, Thomas Lauvaux, Joannes D. Ramón A. Alvarez, Daniel Zavala-Araiza, David R. Lyon, David T. Allen, Zachary R. Barkley, Adam R. Brandt, Kenneth J.

originally published online June 21, 2018DOI: 10.1126/science.aar7204 (6398), 186-188.361Science 

, this issue p. 186Sciencebetter understanding of mitigation efforts outlined by the Paris Agreement.methodology used to obtain them, could improve and verify international inventories of greenhouse gases and provide a because current inventory methods miss emissions that occur during abnormal operating conditions. These data, and thehigher than the U.S. Environmental Protection Agency inventory estimate. They suggest that this discrepancy exists

60%∼ reassessed the magnitude of this leakage and found that in 2015, supply chain emissions were et al.Alvarez Considerable amounts of the greenhouse gas methane leak from the U.S. oil and natural gas supply chain.

A leaky endeavor

ARTICLE TOOLS http://science.sciencemag.org/content/361/6398/186

MATERIALSSUPPLEMENTARY http://science.sciencemag.org/content/suppl/2018/06/20/science.aar7204.DC1

REFERENCES

http://science.sciencemag.org/content/361/6398/186#BIBLThis article cites 60 articles, 8 of which you can access for free

PERMISSIONS http://www.sciencemag.org/help/reprints-and-permissions

Terms of ServiceUse of this article is subject to the

is a registered trademark of AAAS.ScienceScience, 1200 New York Avenue NW, Washington, DC 20005. The title (print ISSN 0036-8075; online ISSN 1095-9203) is published by the American Association for the Advancement ofScience

Science. No claim to original U.S. Government WorksCopyright © 2018 The Authors, some rights reserved; exclusive licensee American Association for the Advancement of

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Cooked with gas Extreme heat in Darwin

The number of days over 35oC in Darwin has increased from 5.6 per year to 22.2 per year. CSIRO

modelling estimates that without climate action this could rise to 132 days per year in 2030 and 275 days

per year in 2070. Such extreme heat would have profound effects on human health, industries and

ecosystems. Given the NT’s vulnerability to climate change, development of emission-intensive oil and

gas reserves are not in the Territory’s interests.

Dr Elizabeth Hanna Mark Ogge March 2018

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ABOUT THE AUSTRALIA INSTITUTE

The Australia Institute is an independent public policy think tank based in Canberra. It is funded by donations from philanthropic trusts and individuals and commissioned research. We barrack for ideas, not political parties or candidates. Since its launch in 1994, the Institute has carried out highly influential research on a broad range of economic, social and environmental issues.

OUR PHILOSOPHY

As we begin the 21st century, new dilemmas confront our society and our planet. Unprecedented levels of consumption co-exist with extreme poverty. Through new technology we are more connected than we have ever been, yet civic engagement is declining. Environmental neglect continues despite heightened ecological awareness. A better balance is urgently needed. The Australia Institute’s directors, staff and supporters represent a broad range of views and priorities. What unites us is a belief that through a combination of research and creativity we can promote new solutions and ways of thinking.

OUR PURPOSE – ‘RESEARCH THAT MATTERS’

The Institute publishes research that contributes to a more just, sustainable and peaceful society. Our goal is to gather, interpret and communicate evidence in order to both diagnose the problems we face and propose new solutions to tackle them. The Institute is wholly independent and not affiliated with any other organisation. Donations to its Research Fund are tax deductible for the donor. Anyone wishing to donate can do so via the website at https://www.tai.org.au or by calling the Institute on 02 6130 0530. Our secure and user-friendly website allows donors to make either one-off or regular monthly donations and we encourage everyone who can to donate in this way as it assists our research in the most significant manner. Level 1, Endeavour House, 1 Franklin St Canberra, ACT 2601 Tel: (02) 61300530 Email: [email protected] Website: www.tai.org.au

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Acknowledgement

The authors wish to acknowledge contributions from Clem Davis (Australian National

University) with aspects of the meteorological data analysis and graph preparation.

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Summary

Temperatures above 35oC with 70% humidity are considered ‘extremely dangerous’ by

government agencies such as the US Government National Oceanic and Atmospheric

Administration. The number of days over 35oC per year in Darwin has increased

fourfold from an average of 5.6 days per year in the early 20th century to over 20 days

per year in the last five years.

This increase is especially pronounced throughout the September to December “build-

up” to the wet season. Combined with the humidity of this season, the resultant heat

stress risk is being pushed to an extremely dangerous level.

Alarmingly, CSIRO climate models project that without drastic reductions in

greenhouse gas emissions, the number of days over 35 degrees each year in Darwin

will increase dramatically to 132 days per year by 2030, 187 days per year by 2050 and

275 days per year by 2070.

Temperature increases of this magnitude are dangerous. Severe health impacts and

heat-related deaths would increase. Increased hot days would reduce productivity in

important Territory industries such as agriculture, construction and tourism.

Ecosystems would be severely damaged and the standard of living of all Territorians

would be greatly reduced.

Exploiting shale oil and gas in the Territory is completely incompatible with the steps

we need to avoid these impacts.

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Introduction

Extreme heat is dangerous for human health, for ecosystems and agriculture. As the

climate warms, the number of extremely hot days is forecast to increase. While Darwin

is known for its consistent warm weather, the number of extremely hot days - days

over 35oC - has generally been low. The number of extremely hot days in Darwin has

increased through the last century and is forecast to increase dramatically without a

strong policy response to climate change.

Animals and plants have an upper limit for heat tolerance. While flora and fauna in the

tropics are adapted for the relatively high temperatures of their environment, the

temperature ranges they experience in tropical regions are very narrow compared to

temperate climate zones. Tropical flora and fauna struggle to survive temperatures

outside the range they are accustomed to, such as extreme heat.1

The human body copes with a wider temperature range via complex thermoregulatory

system. In hot climates, the body cools itself primarily through sweating.2 Evaporation

of sweat transfers heat from the body to the atmosphere. However, when the

surrounding air is hot and humid, heat loss stalls, and the body temperature rises. This

creates discomfort and further heat gain brings a cascade of health impacts, from mild

to severe, and can ultimately be fatal without intervention. Familiarity with heat allows

the body to acclimatize, but this too has upper limits.3

Temperature and humidity are often combined into a heat index figure to provide a

simple indicator of the body’s ability to cool itself. Of a number of indices available,

one of the most important is published by the US Government National Oceanic and

Atmospheric Administration (NOAA).

As shown in the NOAA heat stress chart in Figure 1 below, the combination of

centigrade temperatures in the low thirties with high humidity are considered

“dangerous” to human health.

1 Khaliq I, Hof C, Prinzinger R, Bohning-Gaese K, Pfenninger M. (2014) Global variation in thermal

tolerances and vulnerability of endotherms to climate change. Proc Biol Sci. 2014; 281 (1789):

20141097. 2 Hanna EG, Tait PW. Limitations to thermoregulation and acclimatisation challenges human adaptation

to global warming. Int J Environ Res Public Health (2015) ; 12 (7): 8034-74. 3 Hanna EG, Tait PW. Limitations to thermoregulation and acclimatisation challenges human adaptation

to global warming (2015) Int J Environ Res Public Health 2015; 12 (7): 8034-74.

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Figure 1. NOAA Heat Stress Index

Source: http://www.nws.noaa.gov/os/heat/heat_index.shtml

As shown in Figure 1, NOAA’s heat stress index rises to “Extreme Danger” when

temperatures pass 35oC with 70% humidity. Darwin’s current climate already sees

relative humidity levels approach and even exceeds 70%. From March 2017 to

February 2018 there were 60 days with a relative humidity of 70% or above at 3pm in

Darwin. 46 of these days occurred during the months of January, February and March.4

A future that combines such high humidity levels with a large increase in days over 35

degrees represents a serious threat to the wellbeing of Darwin’s population. Under

such conditions even short period of exposure, particularly in combination physical

exertion, can lead to serious heat disorders and even the risk of death.

Heat stress indices inform the International Standards Organization guidelines for

work-rest ratios to limit the risk of overheating and avoid deaths 5. Temperatures are

recorded in the shade, so the additional heat generated by sunlight adds further to the

risk. According to these guidelines, gentle exercise, such as walking in the sun at 3pm

in Darwin for more than 15 minutes per hour, from September to December (during

the build-up season) already presents dangerous risks of heat stress. 6

Projections about future humidity are mixed. Humidity levels are projected to remain

largely unchanged in the Monsoonal North West of Australia up to 3 degrees of

warming. Over 3 degrees there is thought to be a 34% chance of a small decrease in

4 BOM Daily Weather Observations. http://www.bom.gov.au/climate/dwo/IDCJDW8014.latest.shtml

5 ISO / DIS 7243. Ergonomics of the thermal environment -- Assessment of heat stress using the WBGT (wet bulb

globe temperature) index. Geneva: International Standards Organization; 2015 18th June .p. 16. Available from:

http://www.iso.org/iso/home/store/catalogue_ics/catalogue_detail_ics.htm?csnumber=67188. [cited 30th July

2016]. 6 Davis C, Hanna (2016) EG. Temperature and rainfall trends in Northern Australia 1911-2013:

implications for human activity and regional development. Climate Research. 2016; 71 (1): 1-16.

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humidity (-1 to-10%).7 However, warm air can hold more water vapour, an extra 7% for

every 1oC.8 In a warming world people’s ability to regulate temperature through

sweating may be hampered.

7 CSIRO Climate Change in Australia, Climate Futures Tool, RCP 8.5, 2017. Accessed 15/3/18,

https://www.climatechangeinaustralia.gov.au/en/climate-projections/climate-futures-

tool/projections/ 8 Coumou D, Rahmstorf S. A decade of weather extremes. Nature Clim Change. 2012; 2 (EPub 25

March): 491–6.

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Increasing temperatures in the

Top End

Bureau of Meteorology temperature records are available for Darwin from 1911. On average there were 5.6 days per year over 35oC for the 30-year period from 1911 to 1940. This almost doubled to 10.1 days per year for the years between 1961 and 1990, as shown in Table 1 below:

Table 1: Average number of days per year above 35oC, Darwin

Year Average days over 35oC

1911-1940 5.6

1961-1990 10.1

2008-2017 19.8

2012-2017 22.2 Source: Bureau of Meteorology http://www.bom.gov.au/climate/data/index.shtml

As shown in Table 1 above, the 10 years to 2017 have seen days over 35oC double again to 19.8 days per year. Since 2012, the maximum daily temperature has reached 35oC on average over 22 days per year, representing a fourfold increase since the first half of the 20th century. The Bureau of Meteorology data back to 1911 is represented in Figure 2 below:

Figure 2: Annual number of days over 35oC Darwin, 1911-2016

Source: Analyzed by C. Davis from BoM Acorn_Sat data set.

This recent increase in very hot days has significant implications for human health, productivity and the quality of life of people living in Darwin. Furthermore, the projected increase over the following decades will significantly exacerbate these challenges.

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Projected increases in days over 35oC

The number of extremely hot days in Darwin will increase dramatically in the coming decades under CSIRO climate modelling. Under a business as usual scenario on greenhouse emissions, the CSIRO estimates Darwin could experience days 132 days over 35oC per year in 2030, 187 days per year by 2050 and 275 days per year in 2070. Figure 3 below combines the Bureau of Meteorology’s data on days over 35oC from 1911 with CSIRO predictions out to 2070:

Figure 3: Darwin days over 35oC per year historic and CSIRO future modelling

Source: CSIRO Climate Change in Australia, Climate Thresholds Calculator. Using HadGEM2 RCP

8.5. Accessed 13/3/18 https://www.climatechangeinaustralia.gov.au/en/climate-

projections/explore-data/threshold-calculator/#

These projections are based on the IPCC Representative Concentration Pathways (RCPs) which are scenarios of various levels of concentrations of greenhouse gases in the atmosphere. Here we have used RCP 8.5, which is the highest of the four scenarios of global emissions outlined by the IPCC in their 2014 Fifth Assessment. It reflects the Business as Usual (BAU) scenario, which most closely resembles the current global trajectory as emissions still continue to increase 9.

9 Le Quere C, Andrew RM, Friedlingstein P, Sitch S, Pongratz J, Manning AC, et al. Global carbon budget 2017. Earth

Syst Sci Data. 2017; 8 (13 November): 605–49.

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Figure 3 also shows the projected number of hot days using the RCP 4.5 scenario where strong emission reduction is achieved. The RCP 4.5 pathway requires decisive reduction in emissions. If this is achieved, the CSIRO expects number of days over 35oC per year for Darwin to be significantly lower than in BAU trajectory, with 108 days over 35oC per year in 2030, 143 days per year in 2040 and 178 days per year in 2070. While these figures carry significant inherent risk, substantial additional harm could be avoided. The number of days per year over 35oC under the most ambitious scenario (RCP 2.6) is not shown in Figure 3 as the CSIRO no longer provides these projections. Limiting warming to below 2o C is still possible but would require rapid reductions and deep and profound decarbonization of the global economies(2).10 Insufficient political appetite has been shown thus far to achieve this goal as agreed in Paris in 2015.11 However, it is the only way the Northern Territory can avoid the devastating impacts of dangerous climate change.

10

Raftery AE, Zimmer A, Frierson DMW, Startz R, Liu P. (2017) Less than 2 °C warming by 2100 unlikely.

Nature Climate Change. 2017; 7: 637. 11

UNEP. The Emissions Gap Report 2017. A UN Environment Synthesis Report. Nairobi: United Nations

Environment Programme (UNEP); 2017 31st October p. 116. Available from:

https://wedocs.unep.org/bitstream/handle/20.500.11822/22070/EGR_2017.pdf?sequence=1&isAllow

ed=y. [cited 1st November 2017].

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Distribution of extreme heat days

An indication of the likely timing of extreme heat days throughout the year can be

gained from examining trends from 1911 over the various seasons. As shown in Figure

4, the increase in days over 35oC per year is concentrated in the shoulder seasons, the

“build-up” to the wet season and the transition from the wet to the dry.12 The high

humidity of these seasons combined with the significant increase in extreme heat days

already occurring make this period already dangerous to human health and wellbeing.

Figure 4: Distribution of days over 35oC by season

Note: AM=April-May, SO= Sept-Oct, ND= Nov-Dec. Source: Analyzed by C. Davis from BoM

Acorn_Sat data set.

Note, in Figure 4, the number of days refers to the total over the time period

represented, not the annual average.

Further increase in days over 35 severely increase these impacts. Extreme heat days

can also be expected to increase in other seasons as the total number of extreme heat

days exceeds the amount of days currently making up the shoulder seasons.

12

Davis C, Hanna EG. Temperature and rainfall trends in Northern Australia 1911-2013: implications for human

activity and regional development. Climate Research. 2016; 71 (1): 1-16.

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Consequences of increases in extreme

heat days

There will be a range of consequences from more frequent days of extreme heat, including increased intensity of storms, increasing rainfall extremes, changes to mosquito populations and the way infectious diseases spread. Severe impacts on human health would result, including increased rates of heat-related deaths. Heat interrupts sleep patterns and reduces capacity and willingness to exercise. Both carry broad ramifications, such as increased accident risk,13 avoidance of general life tasks, for example cooking healthy foods, and sedentary life style induced diabetes and cardio vascular disease.14 Europe, Russia, India and Pakistan have all experienced heat waves resulting in mass death events where thousands of people died sitting in their homes. 15,16 Irritability also increases with heat. Darwin experiences strong seasonal patterning in domestic violence and assaults which peak during the build-up season.17 Exacerbations of these incidences would have far reaching effects. The trauma is shocking for victims and their families, and spikes in these violent attacks stretches response capacity of hospital and police services. They also have profoundly negative bearing on social amenity by disrupting community cohesion, sense of safety and attractiveness to visitors and tourists. Recent analysis of decadal climate systems suggests it is possible that the world could breach 1.5oC warming as early as 2026.18 If this happens, within the next decade, Darwin is likely to witness increasingly severe impacts on human health and many more heat related deaths. The ability of the human body to continue to be physically active throughout the day time, for 6 or more months of the year will be significantly curtailed. Later this decade, the number of highly dangerous months could extend to 8 or 9. Many industries such as tourism, construction and agriculture would face challenges just to continue

13

Kjellstrom T, Kovats RS, Lloyd SJ, Holt T, Tol RSJ. The Direct Impact of Climate Change on Regional Labor

Productivity. Archives of Environmental & Occupational Health. 2009; 64 (4): 217-27. 14

WHO. Preventing noncommunicable diseases (NCDs) by reducing environmental risk factors. Geneva; 2017.p. 16.

Report No.: WHO/FWC/EPE/17.1. Available from: http://apps.who.int/iris/bitstream/10665/258796/1/WHO-FWC-

EPE-17.01-eng.pdf?ua=1. [cited 26th September 2017]. 15

Wang H, Horten R. Tackling climate change: the greatest opportunity for health The Lancet Climate Change and

Human Health Commission. 2015;DOI: http://dx.doi.org/10.1016/S0140-6736(15)60854-6(June): 1-2. 16

Hass A, Ellis K, Reyes Mason L, Hathaway J, Howe D. Heat and Humidity in the City: Neighborhood Heat Index

Variability in a Mid-Sized City in the Southeastern United States. International Journal of Environmental Research

and Public Health. 2016; 13 (1): 117. 17

Purtill J. Mango madness: Tropical seasonal affective disorder linked to stress and depression, research finds

Melbourne: ABC News; 2014 [updated 9 Oct Available from: http://www.abc.net.au/news/2014-10-07/mango-

madness-mental-illness-tropical-wet-season-build-up/5795852 18

Henley BJ, King AD. (2017) Trajectories toward the 1.5°C Paris target: Modulation by the Interdecadal Pacific

Oscillation. Geophysical Research Letters. 2017; 44 (9): 4256–62

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operating. In those industries productivity would be impacted, as work-rest ratios will impinge on financial viability. Alternative strategies to facilitate sustained physical exertion outdoors, such as cooling vests and cool rooms will add to costs but are likely to be a necessary feature across Australia’s tropical north.

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Conclusion

Given the vulnerability of Darwin and the rest of the Northern Territory to climate

change, further development of its fossil fuel resources is not in the Territory’s

interests. Such development is incompatible with Australia’s carbon budget and

commitments under the Paris agreement to limit warming to less than 2 degrees. It

has been calculated that two thirds of existing fossil fuel reserves need to remain in

the ground in order to have even a 50% avoid 2 degrees warming.19

Despite this, the Draft Report of the Scientific Inquiry into Hydraulic Fracturing in the

Northern Territory examines a gas production scenario that could result in an increase

of 5% of Australia’s national emissions. A submission from the Northern Territory

Department of Primary Industries and Resources presents an oil and gas production

scenario that would represent an increase of over 20% of Australia’s total annual

emissions. Incredibly, the draft report lists the consequences of these changes in

emissions as “low” and the risk as “medium”.20

Darwin residents are already experiencing the consequences of global warming.

Northern Territory shale oil and gas is a very large potential source of carbon emissions

which should not be developed.

19

McGlade and Ekins (2015) The geographical distribution of fossil fuels unused when limiting global

warming to 2 °C, accessed 15/3/18, https://www.nature.com/articles/nature14016 20

Scientific Inquiry into Hydraulic Fracturing in the Northern Territory (2017) Draft Final Report,

https://frackinginquiry.nt.gov.au/inquiry-reports/draft-final-report

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All It’s Fracked Up to Be 1

All It’s Fracked Up to Be

Government documents released under FOI show annual emissions from fracking for gas in the NT

could be as large as 22% of Australia’s current annual emissions, larger than from all coal stations

expected to be then running in the NEM, and require more offsets every year than have ever been

issued in Australia to date.

Tom Swann

February 2020

The NT’s Scientific Inquiry into Hydraulic Fracturing found that fracking for gas in the

NT threatens greenhouse gas emissions on a very large scale and would cause climate

impacts that would be “unacceptable”. It found that fracking should not be allowed

unless all lifecycle emissions, including combustion of the gas, are fully offset. The NT

Government accepted this recommendation. It removed the moratorium on fracking

for gas, on the condition that all emissions should be offset.

Documents released under Freedom of Information (FOI) show NT and Commonwealth

officials warning that emissions from NT fracking could threaten Australia’s ability to

meet international obligations. They reiterated the need to stop the projects if

offsetting does not occur.1 The documents support Australia Institute research

showing the scale of potential NT fracking emissions.

In the released documents, officials state that emissions from fracking (direct and from

burning the gas) could reach 39 million tonnes of carbon dioxide equivalent (MtCO2e)

per year under one production scenario, and up to 117 MtCO2e per year under larger

scale production.

1 Bardon (2020) How fracking could threaten Australia's Paris target

https://www.abc.net.au/radionational/programs/backgroundbriefing/fracking-could-threaten-

australias-paris-target/12006532 Documents on FOI disclosure log, references 191111, 191110,

http://www.environment.gov.au/about-us/freedom-information/foi-disclosure-log,

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All It’s Fracked Up to Be 2

To put in context the vast scale of these emissions, this is 7% to 22% of Australia’s

current domestic emissions (532 Mt CO2e year to June 2019).2

At their peak, NT fracking emissions would be:

• comparable to annual emissions from all currently operating coal power

stations in the NEM (144 MtCO2e).3

• larger than annual emissions all currently operating black coal power stations

(101 MtCO2e) and,

• larger than annual emissions from all coal fired power stations in the National

Electricity Market (NEM) expected to be operating in the NEM when fracking

occurs (estimated at 107 MtCO2e),

The smaller fracking emissions figure is comparable to annual emissions from all the

old brown coal fired generators in Victoria (estimated at 43 MtCO2e).4

The offsets required to offset NT fracking lifecycle emissions under the larger

production scenario would be larger every year than all Australian Carbon Credit

Units (ACCUs) ever issued by the Australian Government (74 MtCO2e).5

At the smaller figure, annual offsets required four times the offsets delivered each

year under the Emissions Reduction Fund (historically ~10 MtCO2e per year).6

STILL NO OFFSETS POLICY

Nearly two years after the Fracking Inquiry issued its final report, there is still no

credible offsets policy. The NT Government plans to have such a policy in place by the

end of 2021. In the meantime, the NT Government has approved numerous fracking

exploration operations with significant emissions but no offsets, a substantive breach

of its commitment.

2 Department of the Environment (2020) Quarterly Update of Australia’s National Greenhouse Gas

Inventory: June 2019 http://www.environment.gov.au/climate-change/climate-science-

data/greenhouse-gas-measurement/publications/quarterly-update-australias-nggi-jun-2019 3 These calculations are set out in an appendix. 4 These calculations are set out in an appendix. 5 CER (2020) ERF Projects http://www.cleanenergyregulator.gov.au/maps/Pages/erf-projects/index.html 6 CER (2020) http://www.cleanenergyregulator.gov.au/ERF/project-and-contracts-registers/carbon-

abatement-contract-register

Page 25 of 1149

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All It’s Fracked Up to Be 3

A recent ‘Offsets Policy’ document put out by the NT Government gives no further

clarity. The Australia Institute’s submission regarding the Offsets Policy (attached in an

appendix) recommends the policy be amended so that:

1. fracking companies will be required to provide offsets for all domestic scope

1, 2 and 3 emissions, as recommended by the Fracking Inquiry;

2. only ACCUs will be accepted as allowed offsets;

3. the fracking companies pays for these offsets, not the NT Government; and

4. the NT Government maximise benefits accruing to the NT by allowing

mandatory minimum requirements for offsets based in the NT.

Given the NT Government’s decision to allow fracking, the commitment to require full

offsetting is by far the single most important thing the NT Government has promised

to do on climate change – and this is required simply to stop emissions from increasing.

While offsetting is a NT government commitment, the Commonwealth has already

agreed to assist with implementation. The Commonwealth should ensure the

offsetting policy is rigorous and secured prior to any further fracking. As the FOI

documents confirm, failure to offset threatens international obligations to further

reduce emissions.

Page 26 of 1149

Page 27: Wednesday, 08 July 2020 – 15:32:00

All It’s Fracked Up to Be 4

APPENDIX 1: CALCULATION OF COAL EMISSIONS

No data set was found outlining emissions from Australian coal fired power stations.

The list of NEM power stations, their nameplate capacity (MW) and emissions factors

(tCO2e / MWh) were sourced from AEMO.7

This was used to derive emissions assuming all power stations were running all year at full

capacity.

Actual generation for 2017-18 for brown coal and for black coal in relevant NEM states (NSW,

Victoria, Queensland) was sourced from the Australian Energy Statistics.8

This was used to derive the capacity factors (% of maximum generation) for black and brown

coal power stations on the NEM.

This in turn was used to estimate actual emissions from black and brown coal generators.

Power stations were then removed if they are due to close by 2030, according to the

Australian Energy Council, the peak lobby group for power generators.9

Table 1: Emissions estimates for NEM coal power stations

Total brown coal black coal

Capacity MW 23,109 4,690 18,419

hours in year 8,766

MWh at 100% 202,573,494 41,112,540 161,460,954

Actual generation '17-18

36,008,406 110,670,439

capacity factor

88% 69%

tCO2e at 100% capacity 196,385,712 49,295,048 147,090,664

Mt tCO2e at actual capacity 144 43.2 100.8

Mt CO2e at actual capacity, expected operating 2030

107 37.8 69.1

Source: described above

7 AEMO (2020) Carbon Dioxide Equivalent Intensity Index

https://aemo.com.au/en/energy-systems/electricity/national-electricity-market-nem/market-

operations/settlements-and-payments/settlements/carbon-dioxide-equivalent-intensity-index 8 Department of Energy (2019) Australian Energy Update 2019 - Table O

https://www.energy.gov.au/publications/australian-energy-update-2019 9 AEC (2019) Where do we need a new dispatchable power station

https://www.energycouncil.com.au/analysis/where-do-we-need-a-new-dispatchable-power-station/

Page 27 of 1149

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All It’s Fracked Up to Be 5

APPENDIX 2: SUBMISSION RE NT OFFSET POLICY

21 February 2020

To Whom it Concerns,

The Australia Institute welcomes the opportunity to make this submission regarding the NT Government’s Draft Offsets Policy. Our comments relate specifically to offsets for greenhouse gases (GHG). We have attached a previous submission to the NT Climate Policy consultation as it remains directly relevant to this policy.10

The NT’s Scientific Inquiry into Hydraulic Fracturing found the GHG emissions from fracking would cause climate impacts that would be “unacceptable” and so that it should not be allowed unless all lifecycle emissions, including domestic combustion of the gas, are fully offset.

The NT Government accepted this recommendation.

In light of this, the NT Offsets Policy should be revised so that

1. it confirms that fracking companies will be required to provide offsets for all domestic scope 1, 2 and 3 emissions, as recommended by the Fracking Inquiry,

2. only ACCUs will be accepted as allowed offsets, 3. the fracking companies will pay for these offsets, not the NT Government, and 4. the NT Government can maximise benefits accruing to the NT by allowing mandatory

minimum requires for offsets to be delivered from projects based in the NT.

Given the NT Government’s decision to allow fracking, the commitment to require full offsetting is by far the single most important thing the NT Government has promised to do on climate change – and this is required simply to stop emissions from increasing.

To be clear the scale of emissions from one field would be many times greater than proposed emissions savings from the NT government’s 50% renewable energy target.

The NT Government has a laudable 2050 target of net zero emissions and it is encouraging to see actions towards that goal. However if the fracking offset requirement is not implemented in rigorous way, upfront and in full, then it will make it virtually impossible for the NT to make progress towards that goal.

It is deeply concerning that the NT Government has put off resolving the substance of this commitment until the end of 2021, after which point the fracking industry will have begun substantial operations.

10 Online: Swann (2018) Getting Offset https://www.tai.org.au/content/getting-offset-submission-re-nt-

climate-change-discussion-paper

Page 28 of 1149

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All It’s Fracked Up to Be 6

The risk of broken promises and backsliding is clear. Indeed in the meantime, the NT Government has approved a number of exploration fracking operations, allowing additional GHG emissions without any offsetting required, a breach of the commitment to require full offsetting of all emissions from fracking.

The offsets policy contains entirely laudable general principles regarding the use of offsets. But it gives little clarity regarding how offsets will be required.

This can and should be resolved very quickly.

As per the clear recommendation of the Fracking Inquiry, all domestic scope 1, 2 and 3 emissions should be offset. These are easy to calculate from Commonwealth government emissions factors.

(Note the scope 1 factors for fugitives are problematically low, with new research frequently demonstrating high fugitive methane emissions are not properly accounted for. But the existence of national factors nonetheless allows easy calculation.)

The offsets required should be credible, certified under the National Carbon Offsets Scheme as Accredited Carbon Credit Units (ACCUs). Methodologies for accrediting ACCUs are developed and approved by a statutory Commonwealth agency. Gas companies, or indeed the NT government, can apply to have new methods considered.

The draft Offsets policy only mentions ACCUs and does not mention other, less credible forms of offsets. This is welcome and suggests that the NT government will only allow ACCUs.

However the suggestion is not a clear commitment. This is easily fixed. The policy should state that only ACCUs will be accepted.

The NT Government could readily impose a minimum mandated requirement for a share of ACCUs sourced from activities in the NT.

All of these proposed revisions to the NT Draft Offsets policy represent the existing substantive commitment of the NT Government and are easily implemented within existing federal government carbon governance frameworks.

For the NT Government not to make such revisions, or to make them explicit in some other policy document, will only further heighten concerns about the NT Government’s commitment to this very important policy commitment.

We would welcome the opportunity to discuss further with the Department.

Sincerely,

Tom Swann Senior Researcher The Australia Institute

Page 29 of 1149

Page 30: Wednesday, 08 July 2020 – 15:32:00

Abela, D – Friday, 24 July 2020 – 17:51:09Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From D AbelaSent 7/24/2020 5:51:09 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 30 of 1149

Page 31: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 31 of 1149

Page 32: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 32 of 1149

Page 33: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

D Abela

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by D Abela via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverD provided an email address (*************) which we included in the REPLY-TO field.

Please reply to D Abela at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 33 of 1149

Page 34: Wednesday, 08 July 2020 – 15:32:00

ALBRECHT, Heather – Thursday, 23 July 2020 – 12:15:12Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Heather ALBRECHTSent 7/23/2020 12:15:12 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 34 of 1149

Page 35: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 35 of 1149

Page 36: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 36 of 1149

Page 37: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Heather ALBRECHT

Minyama, Queensland, 4575, Australia

___________________________

This email was sent by Heather ALBRECHT via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Heather provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Heather ALBRECHT at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 37 of 1149

Page 38: Wednesday, 08 July 2020 – 15:32:00

Alderman, Daniel – Saturday, 25 July 2020 – 16:54:49Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Daniel AldermanSent 7/25/2020 4:54:49 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 38 of 1149

Page 39: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 39 of 1149

Page 40: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 40 of 1149

Page 41: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

************* Alderman

Darwin City, Northern Territory, 0800, Australia

___________________________

This email was sent by Daniel Alderman via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Daniel provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Daniel Alderman at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 41 of 1149

Page 42: Wednesday, 08 July 2020 – 15:32:00

Alexander, Ashok – Friday, 31 July 2020 – 13:25:31Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Ashok AlexanderSent 7/31/2020 1:25:31 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 42 of 1149

Page 43: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 43 of 1149

Page 44: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 44 of 1149

Page 45: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Ashok Alexander

Darwin City, Northern Territory, 0800, Australia

___________________________

This email was sent by Ashok Alexander via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Ashok provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Ashok Alexander at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 45 of 1149

Page 46: Wednesday, 08 July 2020 – 15:32:00

Ambler, Susan – Monday, 20 July 2020 – 22:27:19Subject Objection Imperial Oil and Gas wet season drilling program EP 187From Susan AmblerSent 7/20/2020 10:27:19 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

Page 46 of 1149

Page 47: Wednesday, 08 July 2020 – 15:32:00

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

Page 47 of 1149

Page 48: Wednesday, 08 July 2020 – 15:32:00

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Page 48 of 1149

Page 49: Wednesday, 08 July 2020 – 15:32:00

Yours sincerely,

Susan Ambler

• Katoomba DC, New South Wales, 2780, Australia

___________________________

This email was sent by Susan Ambler via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Susan provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Susan Ambler at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 49 of 1149

Page 50: Wednesday, 08 July 2020 – 15:32:00

Ambridge, Samantha – Tuesday, 28 July 2020 – 14:25:25Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Samantha AmbridgeSent 7/28/2020 2:25:25 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 50 of 1149

Page 51: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 51 of 1149

Page 52: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 52 of 1149

Page 53: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Samantha Ambridge

Virginia, Northern Territory, 0834, Australia

___________________________

This email was sent by Samantha Ambridge via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Samantha provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Samantha Ambridge at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 53 of 1149

Page 54: Wednesday, 08 July 2020 – 15:32:00

AmorRobertson, Jordan – Monday, 20 July 2020 – 12:21:07Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jordan Amor-RobertsonSent 7/20/2020 12:21:07 PM

Dear Department of Environment and Natural Resources,

There is no future in fracking. In addition to the significant environmental concerns, it isincreasingly clear that this is not a financially sustainable endeavour. The future is inrenewables.

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, water

Page 54 of 1149

Page 55: Wednesday, 08 July 2020 – 15:32:00

and the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

Page 55 of 1149

Page 56: Wednesday, 08 July 2020 – 15:32:00

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

Page 56 of 1149

Page 57: Wednesday, 08 July 2020 – 15:32:00

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jordan Amor-Robertson

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Jordan Amor-Robertson via Do Gooder, a website that allows peopleto contact you regarding issues they consider important. In accordance with web protocolRFC 3834 we have set the FROM field of this email to our generic no-reply address at*************, however Jordan provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Jordan Amor-Robertson at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 57 of 1149

Page 58: Wednesday, 08 July 2020 – 15:32:00

Armstrong, Valerie – Friday, 24 July 2020 – 11:29:55Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Valerie ArmstrongSent 7/24/2020 11:29:55 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 58 of 1149

Page 59: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 59 of 1149

Page 60: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 60 of 1149

Page 61: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Valerie Armstrong

Longwarry North, Victoria, 3816, Australia

___________________________

This email was sent by Valerie Armstrong via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Valerie provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Valerie Armstrong at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 61 of 1149

Page 62: Wednesday, 08 July 2020 – 15:32:00

Arthur, Kylie – Thursday, 30 July 2020 – 11:53:43Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Kylie ArthurSent 7/30/2020 11:53:43 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 62 of 1149

Page 63: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 63 of 1149

Page 64: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 64 of 1149

Page 65: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Kylie Arthur

Darwin City, Northern Territory, 0800, Australia

___________________________

This email was sent by Kylie Arthur via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Kylie provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Kylie Arthur at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 65 of 1149

Page 66: Wednesday, 08 July 2020 – 15:32:00

Asmar, Soraya – Tuesday, 28 July 2020 – 21:31:12Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Soraya AsmarSent 7/28/2020 9:31:12 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 66 of 1149

Page 67: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 67 of 1149

Page 68: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 68 of 1149

Page 69: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Soraya Asmar

___________________________

This email was sent by Soraya Asmar via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Soraya provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Soraya Asmar at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 69 of 1149

Page 70: Wednesday, 08 July 2020 – 15:32:00

Asplin, Jennifer – Monday, 20 July 2020 – 16:18:34Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jennifer AsplinSent 7/20/2020 4:18:34 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 70 of 1149

Page 71: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 71 of 1149

Page 72: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 72 of 1149

Page 73: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

jennifer asplin

New South Wales, 2540, Australia

___________________________

This email was sent by jennifer asplin via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however jennifer provided an email address (*************) which we included in theREPLY-TO field.

Please reply to jennifer asplin at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 73 of 1149

Page 74: Wednesday, 08 July 2020 – 15:32:00

Atkinson, Max – Thursday, 30 July 2020 – 19:08:00Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Max AtkinsonSent 7/30/2020 7:08:00 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 74 of 1149

Page 75: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 75 of 1149

Page 76: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 76 of 1149

Page 77: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Max Atkinson

Millner, Northern Territory, 0810, Australia

___________________________

This email was sent by Max Atkinson via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Max provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Max Atkinson at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 77 of 1149

Page 78: Wednesday, 08 July 2020 – 15:32:00

Barbour, Georgina – Tuesday, 28 July 2020 – 19:17:57Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Georgina BarbourSent 7/28/2020 7:17:57 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 78 of 1149

Page 79: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 79 of 1149

Page 80: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 80 of 1149

Page 81: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Georgina Barbour

Berry Springs, Northern Territory, 0838, Australia

___________________________

This email was sent by Georgina Barbour via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Georgina provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Georgina Barbour at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 81 of 1149

Page 82: Wednesday, 08 July 2020 – 15:32:00

Beaux, Pippa – Tuesday, 28 July 2020 – 13:51:43Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Pippa De BeauxSent 7/28/2020 1:51:43 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

14 million acres is a lot of wells. A lot of wells intercepting gas horizons and aquifers. Wellsthat will exist forever. With "no specific considerations" for how these will be rehabilitated ormaintained forever and a change of hand after 3 years, who will take responsibility for whenthe aquifers become polluted? American companies? Is there anything they can realisticallydo once a well fails to reverse the environmental damage it's caused?

And who's name will be on the document approving this to go ahead? With a globaloversupply of gas and lower demand due to global economic downturn the time for closureand rehabilitation may come sooner that Imperial would like. Even with short memories I'msure we will recall who gave fracking the go ahead in the NT and who failed in their duties toprotect the NT environment.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

Page 82 of 1149

Page 83: Wednesday, 08 July 2020 – 15:32:00

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

Page 83 of 1149

Page 84: Wednesday, 08 July 2020 – 15:32:00

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

Page 84 of 1149

Page 85: Wednesday, 08 July 2020 – 15:32:00

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Pippa De Beaux

___________________________

This email was sent by Pippa De Beaux via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Pippa provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Pippa De Beaux at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 85 of 1149

Page 86: Wednesday, 08 July 2020 – 15:32:00

Beck, Joy – Monday, 20 July 2020 – 12:02:20Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Joy BeckSent 7/20/2020 12:02:20 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 86 of 1149

Page 87: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 87 of 1149

Page 88: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 88 of 1149

Page 89: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Joy Beck

Howard Springs, Northern Territory, 0835, Australia

___________________________

This email was sent by Joy Beck via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverJoy provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Joy Beck at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 89 of 1149

Page 90: Wednesday, 08 July 2020 – 15:32:00

Blake, Kim – Friday, 24 July 2020 – 08:12:54Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Kim BlakeSent 7/24/2020 8:12:54 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 90 of 1149

Page 91: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 91 of 1149

Page 92: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 92 of 1149

Page 93: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Kim Blake

South Melbourne, Victoria, 3205, Australia

___________________________

This email was sent by Kim Blake via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverKim provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Kim Blake at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 93 of 1149

Page 94: Wednesday, 08 July 2020 – 15:32:00

Boer, Kate – Friday, 31 July 2020 – 14:38:19Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Kate De BoerSent 7/31/2020 2:38:19 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 94 of 1149

Page 95: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 95 of 1149

Page 96: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 96 of 1149

Page 97: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Kate de Boer

Mount Helena, Western Australia, 6082, Australia

___________________________

This email was sent by Kate de Boer via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Kate provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Kate de Boer at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 97 of 1149

Page 98: Wednesday, 08 July 2020 – 15:32:00

Bollard, Tony – Thursday, 30 July 2020 – 17:16:18Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Tony BollardSent 7/30/2020 5:16:18 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 98 of 1149

Page 99: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 99 of 1149

Page 100: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 100 of 1149

Page 101: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Tony Bollard

Borroloola, Northern Territory, 0854, Australia

___________________________

This email was sent by Tony Bollard via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Tony provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Tony Bollard at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 101 of 1149

Page 102: Wednesday, 08 July 2020 – 15:32:00

Borchers, Clinton – Tuesday, 21 July 2020 – 18:00:31Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Clinton BorchersSent 7/21/2020 6:00:31 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 102 of 1149

Page 103: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 103 of 1149

Page 104: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 104 of 1149

Page 105: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

clinton borchers

Enoggera Reservoir, Queensland, 4520, Australia

___________________________

This email was sent by clinton borchers via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however clinton provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to clinton borchers at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 105 of 1149

Page 106: Wednesday, 08 July 2020 – 15:32:00

Bosold, Patrick – Tuesday, 21 July 2020 – 01:22:47Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Patrick BosoldSent 7/21/2020 1:22:47 AM

Dear Department of Environment and Natural Resources,

Having traveled through the Northern Territory some years ago, I have an appreciation for thecountry and its vulnerability to disruption by mining and other extraction activities, especiallyduring the wet/monsoon season.

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, water

Page 106 of 1149

Page 107: Wednesday, 08 July 2020 – 15:32:00

and the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue are proposed to be initially stored in a lined pit. Subject tosampling and testing results, drill cuttings will be buried and disposed in-situ (on site). Thisdisposal of potentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal, then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough. If this waste is too dangerous for theNT, why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

Page 107 of 1149

Page 108: Wednesday, 08 July 2020 – 15:32:00

The McArthur River is the primary surface water, and is the water drain of the explorationarea. This water course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

Page 108 of 1149

Page 109: Wednesday, 08 July 2020 – 15:32:00

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Patrick Bosold

Fairfield, Iowa, 52556, United States

___________________________

This email was sent by Patrick Bosold via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Patrick provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Patrick Bosold at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 109 of 1149

Page 110: Wednesday, 08 July 2020 – 15:32:00

Boxsell, Gregory – Monday, 20 July 2020 – 13:47:49Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Gregory BoxsellSent 7/20/2020 1:47:49 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 110 of 1149

Page 111: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 111 of 1149

Page 112: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 112 of 1149

Page 113: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Gregory Boxsell

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Gregory Boxsell via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Gregory provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Gregory Boxsell at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 113 of 1149

Page 114: Wednesday, 08 July 2020 – 15:32:00

Bradstreet, Dion – Thursday, 30 July 2020 – 18:28:32Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Dion BradstreetSent 7/30/2020 6:28:32 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 114 of 1149

Page 115: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 115 of 1149

Page 116: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Dion BradstreetEighty Mile Beach, Western Australia, 6725, Australia

___________________________

Page 116 of 1149

Page 117: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Dion Bradstreet via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Dion provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Dion Bradstreet at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 117 of 1149

Page 118: Wednesday, 08 July 2020 – 15:32:00

Brand, Jeanette – Monday, 20 July 2020 – 17:23:57Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jeanette BrandSent 7/20/2020 5:23:57 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 118 of 1149

Page 119: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 119 of 1149

Page 120: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 120 of 1149

Page 121: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jeanette Brand

Bona Vista, Victoria, 3820, Australia

___________________________

This email was sent by Jeanette Brand via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Jeanette provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Jeanette Brand at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 121 of 1149

Page 122: Wednesday, 08 July 2020 – 15:32:00

Brand, Michael – Tuesday, 21 July 2020 – 12:33:42Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Michael BrandSent 7/21/2020 12:33:42 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 122 of 1149

Page 123: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 123 of 1149

Page 124: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 124 of 1149

Page 125: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Michael Brand

Marrara, Northern Territory, 0812, Australia

___________________________

This email was sent by Michael Brand via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Michael provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Michael Brand at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 125 of 1149

Page 126: Wednesday, 08 July 2020 – 15:32:00

Broadfield, Anteo – Monday, 20 July 2020 – 17:34:26Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Anteo BroadfieldSent 7/20/2020 5:34:26 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 126 of 1149

Page 127: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 127 of 1149

Page 128: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 128 of 1149

Page 129: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Anteo Broadfield

Blackstone Heights, Tasmania, 7250, Australia

___________________________

This email was sent by Anteo Broadfield via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Anteo provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Anteo Broadfield at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 129 of 1149

Page 130: Wednesday, 08 July 2020 – 15:32:00

Brown, Louise – Monday, 20 July 2020 – 20:51:42Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Louise BrownSent 7/20/2020 8:51:42 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 130 of 1149

Page 131: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 131 of 1149

Page 132: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 132 of 1149

Page 133: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Louise Brown

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Louise Brown via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Louise provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Louise Brown at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 133 of 1149

Page 134: Wednesday, 08 July 2020 – 15:32:00

Brown, SallyAnne – Monday, 20 July 2020 – 21:34:56Subject Reckless profiteering plans to shore up investor profiles: Objection to Imperial Oil and

Gas wet season drilling program EP 187From Sally-Anne BrownSent 7/20/2020 9:34:56 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.It is destructive at every essential resource level: land air water and therefore, ecosystem.There are alternative strategies for energy that don't require damaging these. Full stop.Detail you already know but are at risk of ignoring :IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

Page 134 of 1149

Page 135: Wednesday, 08 July 2020 – 15:32:00

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental and

Page 135 of 1149

Page 136: Wednesday, 08 July 2020 – 15:32:00

Baseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Sally-Anne BrownNew South Wales, 2550, Australia

Page 136 of 1149

Page 137: Wednesday, 08 July 2020 – 15:32:00

___________________________This email was sent by Sally-Anne Brown via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Sally-Anne provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Sally-Anne Brown at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 137 of 1149

Page 138: Wednesday, 08 July 2020 – 15:32:00

Browning, Joan – Tuesday, 21 July 2020 – 07:51:53Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Joan BrowningSent 7/21/2020 7:51:53 AM

Dear Department of Environment and Natural Resources,

I object to the Revised Environmental Management Plan submitted by Imperial Oil and Gasfor their 2020 Drilling Program NT Exploration Permit (EP) 187.

My key concerns are:

IMPACTS TO PEOPLE AND COMMUNITIES

Possible negative impacts to people and communities posed by Imperial’s drilling programinclude:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are pastoral properties with livestock and infrastructure in the vicinity or the Tenement.OT Downs Homestead is approximately 20km North-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

Page 138 of 1149

Page 139: Wednesday, 08 July 2020 – 15:32:00

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

Page 139 of 1149

Page 140: Wednesday, 08 July 2020 – 15:32:00

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Page 140 of 1149

Page 141: Wednesday, 08 July 2020 – 15:32:00

Thank you for considering my concerns,

Yours sincerely,

Joan Browning

Bar Beach, New South Wales, 2300, Australia

___________________________

This email was sent by Joan Browning via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Joan provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Joan Browning at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 141 of 1149

Page 142: Wednesday, 08 July 2020 – 15:32:00

Brownrigg, Jane – Wednesday, 22 July 2020 – 14:43:28Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jane BrownriggSent 7/22/2020 2:43:28 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 142 of 1149

Page 143: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 143 of 1149

Page 144: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 144 of 1149

Page 145: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jane Brownrigg

Fairfield, Victoria, 3078, Australia

___________________________

This email was sent by Jane Brownrigg via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Jane provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Jane Brownrigg at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 145 of 1149

Page 146: Wednesday, 08 July 2020 – 15:32:00

Burns, David – Monday, 20 July 2020 – 10:54:33Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From David BurnsSent 7/20/2020 10:54:33 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 146 of 1149

Page 147: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 147 of 1149

Page 148: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 148 of 1149

Page 149: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

david burns

Bilyana, Queensland, 4854, Australia

___________________________

This email was sent by david burns via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however david provided an email address (*************) which we included in theREPLY-TO field.

Please reply to david burns at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 149 of 1149

Page 150: Wednesday, 08 July 2020 – 15:32:00

Campbell, Merinda – Thursday, 23 July 2020 – 08:06:38Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Merinda CampbellSent 7/23/2020 8:06:38 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 150 of 1149

Page 151: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 151 of 1149

Page 152: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 152 of 1149

Page 153: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Merinda Campbell

Darwin DC, Northern Territory, 0820, Australia

___________________________

This email was sent by Merinda Campbell via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Merinda provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Merinda Campbell at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 153 of 1149

Page 154: Wednesday, 08 July 2020 – 15:32:00

Carew, Janet – Tuesday, 28 July 2020 – 10:07:59Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Janet CarewSent 7/28/2020 10:07:59 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 154 of 1149

Page 155: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 155 of 1149

Page 156: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 156 of 1149

Page 157: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Janet Carew

Diamond Valley, Queensland, 4553, Australia

___________________________

This email was sent by Janet Carew via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Janet provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Janet Carew at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 157 of 1149

Page 158: Wednesday, 08 July 2020 – 15:32:00

Carland, Susanne – Thursday, 30 July 2020 – 15:13:16Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Susanne CarlandSent 7/30/2020 3:13:16 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 158 of 1149

Page 159: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 159 of 1149

Page 160: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 160 of 1149

Page 161: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Susanne Carland

Perth, Western Australia, 6000, Australia

___________________________

This email was sent by Susanne Carland via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Susanne provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Susanne Carland at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 161 of 1149

Page 162: Wednesday, 08 July 2020 – 15:32:00

Carvalho, Natacha – Friday, 24 July 2020 – 17:16:48Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Natacha CarvalhoSent 7/24/2020 5:16:48 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 162 of 1149

Page 163: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 163 of 1149

Page 164: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 164 of 1149

Page 165: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Natacha Carvalho

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Natacha Carvalho via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Natacha provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Natacha Carvalho at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 165 of 1149

Page 166: Wednesday, 08 July 2020 – 15:32:00

Cashin, MargaretMary – Monday, 20 July 2020 – 21:59:33Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Margaret-Mary CashinSent 7/20/2020 9:59:33 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 166 of 1149

Page 167: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 167 of 1149

Page 168: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 168 of 1149

Page 169: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Margaret-Mary Cashin

Batman, Victoria, 3058, Australia

___________________________

This email was sent by Margaret-Mary Cashin via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Margaret-Mary provided an email address (*************) whichwe included in the REPLY-TO field.

Please reply to Margaret-Mary Cashin at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 169 of 1149

Page 170: Wednesday, 08 July 2020 – 15:32:00

Ceh, Evica – Thursday, 30 July 2020 – 18:03:40Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Evica CehSent 7/30/2020 6:03:40 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 170 of 1149

Page 171: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 171 of 1149

Page 172: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Evica Ceh

___________________________

Page 172 of 1149

Page 173: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Evica Ceh via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverEvica provided an email address (*************) which we included in the REPLY-TOfield.

Please reply to Evica Ceh at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 173 of 1149

Page 174: Wednesday, 08 July 2020 – 15:32:00

Chadderton, John – Monday, 20 July 2020 – 12:17:26Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From John ChaddertonSent 7/20/2020 12:17:26 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 174 of 1149

Page 175: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 175 of 1149

Page 176: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 176 of 1149

Page 177: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

John Chadderton

Footscray, Victoria, 3011, Australia

___________________________

This email was sent by John Chadderton via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however John provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to John Chadderton at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 177 of 1149

Page 178: Wednesday, 08 July 2020 – 15:32:00

Chalmers, Elizabeth – Saturday, 25 July 2020 – 20:02:55Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Elizabeth ChalmersSent 7/25/2020 8:02:55 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 178 of 1149

Page 179: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 179 of 1149

Page 180: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 180 of 1149

Page 181: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Elizabeth Chalmers

Tarrawanna, New South Wales, 2518, Australia

___________________________

This email was sent by Elizabeth Chalmers via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Elizabeth provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Elizabeth Chalmers at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 181 of 1149

Page 182: Wednesday, 08 July 2020 – 15:32:00

Chapel, Jessica – Tuesday, 28 July 2020 – 11:20:54Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jessica ChapelSent 7/28/2020 11:20:54 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 182 of 1149

Page 183: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 183 of 1149

Page 184: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 184 of 1149

Page 185: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jessica Chapel

___________________________

This email was sent by Jessica Chapel via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Jessica provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Jessica Chapel at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 185 of 1149

Page 186: Wednesday, 08 July 2020 – 15:32:00

Clarke, Matthew – Tuesday, 21 July 2020 – 00:35:42Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Matthew ClarkeSent 7/21/2020 12:35:42 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 186 of 1149

Page 187: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 187 of 1149

Page 188: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 188 of 1149

Page 189: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Matthew Clarke

___________________________

This email was sent by Matthew Clarke via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Matthew provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Matthew Clarke at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 189 of 1149

Page 190: Wednesday, 08 July 2020 – 15:32:00

Clifford, Jane – Thursday, 30 July 2020 – 19:20:17Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jane CliffordSent 7/30/2020 7:20:17 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 190 of 1149

Page 191: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 191 of 1149

Page 192: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns, my philanthropy supports the environment and myconcerns for threatened species. We can’t risk our environment and as Rio Tinto recentlyproved, we don’t need anymore agents of environmental and cultural vandalism.

Yours sincerely,Jane CliffordBirchgrove, New South Wales, 2041, Australia

Page 192 of 1149

Page 193: Wednesday, 08 July 2020 – 15:32:00

___________________________This email was sent by Jane Clifford via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Jane provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Jane Clifford at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 193 of 1149

Page 194: Wednesday, 08 July 2020 – 15:32:00

Conje, Barbara – Tuesday, 28 July 2020 – 12:20:07Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Barbara ConjeSent 7/28/2020 12:20:07 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 194 of 1149

Page 195: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 195 of 1149

Page 196: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 196 of 1149

Page 197: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Barbara Conje

___________________________

This email was sent by Barbara Conje via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Barbara provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Barbara Conje at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 197 of 1149

Page 198: Wednesday, 08 July 2020 – 15:32:00

Connolly, Niall – Friday, 24 July 2020 – 09:12:27Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Niall ConnollySent 7/24/2020 9:12:27 AM

Dear Department of Environment and Natural Resources,

As a former long term resident of Darwin in the Northern Territory I am writing to expressmy objection to the Revised Environmental Management Plan submitted by Imperial Oil andGas for their 2020 Drilling Program NT Exploration Permit (EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 198 of 1149

Page 199: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 199 of 1149

Page 200: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 200 of 1149

Page 201: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Niall Connolly

___________________________

This email was sent by Niall Connolly via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Niall provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Niall Connolly at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 201 of 1149

Page 202: Wednesday, 08 July 2020 – 15:32:00

Conroy, Bodil – Monday, 20 July 2020 – 15:36:41Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Bodil ConroySent 7/20/2020 3:36:41 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 202 of 1149

Page 203: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 203 of 1149

Page 204: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 204 of 1149

Page 205: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Bodil Conroy

Moulden, Northern Territory, 0830, Australia

___________________________

This email was sent by Bodil Conroy via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Bodil provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Bodil Conroy at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 205 of 1149

Page 206: Wednesday, 08 July 2020 – 15:32:00

Conway, Sylvia – Thursday, 30 July 2020 – 10:10:19Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Sylvia ConwaySent 7/30/2020 10:10:19 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 206 of 1149

Page 207: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 207 of 1149

Page 208: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 208 of 1149

Page 209: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

sylvia Conway

Koah, Queensland, 4881, Australia

___________________________

This email was sent by sylvia Conway via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however sylvia provided an email address (*************) which we included in theREPLY-TO field.

Please reply to sylvia Conway at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 209 of 1149

Page 210: Wednesday, 08 July 2020 – 15:32:00

CROWE, JUDITH – Tuesday, 21 July 2020 – 11:37:31Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From JUDITH CROWESent 7/21/2020 11:37:31 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 210 of 1149

Page 211: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 211 of 1149

Page 212: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 212 of 1149

Page 213: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

JUDITH CROWE

Heddon Greta, New South Wales, 2321, Australia

___________________________

This email was sent by JUDITH CROWE via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however JUDITH provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to JUDITH CROWE at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 213 of 1149

Page 214: Wednesday, 08 July 2020 – 15:32:00

Czerniak, Anthony – Thursday, 23 July 2020 – 07:13:54Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Anthony CzerniakSent 7/23/2020 7:13:54 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 214 of 1149

Page 215: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 215 of 1149

Page 216: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 216 of 1149

Page 217: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Anthony Czerniak via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Anthony provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Anthony Czerniak at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 217 of 1149

Page 218: Wednesday, 08 July 2020 – 15:32:00

Dall, Skylen – Friday, 31 July 2020 – 07:25:33Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Skylen DallSent 7/31/2020 7:25:33 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 218 of 1149

Page 219: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 219 of 1149

Page 220: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 220 of 1149

Page 221: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Skylen Dall

Curtin, Australian Capital Territory, 2605, Australia

___________________________

This email was sent by Skylen Dall via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Skylen provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Skylen Dall at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 221 of 1149

Page 222: Wednesday, 08 July 2020 – 15:32:00

Davey, Roger – Tuesday, 28 July 2020 – 22:00:38Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Roger DaveySent 7/28/2020 10:00:38 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 222 of 1149

Page 223: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 223 of 1149

Page 224: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 224 of 1149

Page 225: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Roger Davey

Girraween, Northern Territory, 0836, Australia

___________________________

This email was sent by Roger Davey via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Roger provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Roger Davey at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 225 of 1149

Page 226: Wednesday, 08 July 2020 – 15:32:00

Delamere, Carlos – Monday, 20 July 2020 – 11:27:12Subject I oppose the Imperial Oil and Gas wet season drilling program EP 187!From Carlos DelamereSent 7/20/2020 11:27:12 AM

Dear Department of Environment and Natural Resources,

It's unfortunate that time and time again we have to witness the further destruction of people'swellbeing and the earth we reside on because of the greed of others. That is why I am writingto express my objection to the Revised Environmental Management Plan submitted byImperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit (EP) 187.

Key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

Page 226 of 1149

Page 227: Wednesday, 08 July 2020 – 15:32:00

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

Page 227 of 1149

Page 228: Wednesday, 08 July 2020 – 15:32:00

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Page 228 of 1149

Page 229: Wednesday, 08 July 2020 – 15:32:00

Thank you for considering my concerns. Do you want to support the destruction of life on thisplanet and erode away what's left of this beautiful country or support the change to make thisplace a positve and inhabitable environment for all life for centuries to come?

Yours sincerely,

Carlos Delamere

Burnside, Queensland, Australia

___________________________

This email was sent by Carlos Delamere via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Carlos provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Carlos Delamere at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 229 of 1149

Page 230: Wednesday, 08 July 2020 – 15:32:00

Delaney, Katherine – Tuesday, 21 July 2020 – 19:46:27Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Katherine DelaneySent 7/21/2020 7:46:27 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns match those of most I imagine but I was brought up in this beautiful part ofAustralia for the first half of my childhood. And this is sucha threat to this beautifulecosystem. Please take the following objections into consideration and do not allow thispermit .

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

Page 230 of 1149

Page 231: Wednesday, 08 July 2020 – 15:32:00

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Page 231 of 1149

Page 232: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Page 232 of 1149

Page 233: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Best wishes,

Katherine Delaney

___________________________

This email was sent by Katherine Delaney via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Katherine provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Katherine Delaney at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 233 of 1149

Page 234: Wednesday, 08 July 2020 – 15:32:00

Denholm, Hilary – Monday, 20 July 2020 – 13:33:09Subject Submission to Object to Imperial Oil and Gas Program EP 187From Hilary DenholmSent 7/20/2020 1:33:09 PM

Dear Department of Environment and Natural Resources,

I am a teacher and grandmother living in Sydney and doing everything I can to protect ourbeautiful country (and planet) for my grandchildren.

So I am writing to strongly object to the Revised Environmental Management Plan submittedby Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit (EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

Page 234 of 1149

Page 235: Wednesday, 08 July 2020 – 15:32:00

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Page 235 of 1149

Page 236: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Page 236 of 1149

Page 237: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns, all of which are very important. It is hard to believethat you could ignore the urgent necessity to stop all such programs.

Yours sincerely,

Hilary Denholm

Waverley, New South Wales, 2024, Australia

___________________________

This email was sent by Hilary Denholm via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Hilary provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Hilary Denholm at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 237 of 1149

Page 238: Wednesday, 08 July 2020 – 15:32:00

Denner, Shon – Sunday, 26 July 2020 – 12:11:00Subject SUPPORT to Imperial Oil and Gas wet season drilling program EP 187From Shon DennerSent 7/26/2020 12:11:00 PM

Dear Department of Environment and Natural Resources,

I am writing to express my SUPPORT to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

Yours sincerely,Shon DennerDarwin City, Northern Territory, 0800, Australia

___________________________This email was sent by Shon Denner via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Shon provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Shon Denner at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 238 of 1149

Page 239: Wednesday, 08 July 2020 – 15:32:00

Diaz, Susy – Friday, 31 July 2020 – 14:55:06Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Susy DiazSent 7/31/2020 2:55:06 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 239 of 1149

Page 240: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 240 of 1149

Page 241: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 241 of 1149

Page 242: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Susy Diaz via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverSusy provided an email address (*************) which we included in the REPLY-TOfield.

Please reply to Susy Diaz at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 242 of 1149

Page 243: Wednesday, 08 July 2020 – 15:32:00

Diggles, Russell – Monday, 20 July 2020 – 12:57:39Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Russell DigglesSent 7/20/2020 12:57:39 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 243 of 1149

Page 244: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 244 of 1149

Page 245: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 245 of 1149

Page 246: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Russell Diggles

Burpengary, Queensland, 4505, Australia

___________________________

This email was sent by Russell Diggles via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Russell provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Russell Diggles at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 246 of 1149

Page 247: Wednesday, 08 July 2020 – 15:32:00

Dixon, Peter – Monday, 20 July 2020 – 13:01:25Subject I Object to Imperial Oil and Gas wet season drilling program EP 187From Peter DixonSent 7/20/2020 1:01:25 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 247 of 1149

Page 248: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 248 of 1149

Page 249: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 249 of 1149

Page 250: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Peter Dixon

Paterson Street

TENNANT CREEK

Yours sincerely,

Peter Dixon

Tennant Creek, Northern Territory, 0860, Australia

___________________________

This email was sent by Peter Dixon via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Peter provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Peter Dixon at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 250 of 1149

Page 251: Wednesday, 08 July 2020 – 15:32:00

Doecke, Susanne – Thursday, 23 July 2020 – 18:32:47Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Susanne DoeckeSent 7/23/2020 6:32:47 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 251 of 1149

Page 252: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 252 of 1149

Page 253: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 253 of 1149

Page 254: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Susanne Doecke

White Gums, Northern Territory, 0870, Australia

___________________________

This email was sent by Susanne Doecke via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Susanne provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Susanne Doecke at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 254 of 1149

Page 255: Wednesday, 08 July 2020 – 15:32:00

Doyle, Jorgen – Tuesday, 28 July 2020 – 17:22:51Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jorgen DoyleSent 7/28/2020 5:22:51 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 255 of 1149

Page 256: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 256 of 1149

Page 257: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 257 of 1149

Page 258: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jorgen Doyle

White Gums, Northern Territory, 0870, Australia

___________________________

This email was sent by Jorgen Doyle via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Jorgen provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Jorgen Doyle at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 258 of 1149

Page 259: Wednesday, 08 July 2020 – 15:32:00

Duigu, Gabrielle – Monday, 20 July 2020 – 12:22:10Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Gabrielle DuiguSent 7/20/2020 12:22:10 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 259 of 1149

Page 260: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 260 of 1149

Page 261: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 261 of 1149

Page 262: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Gabrielle Duigu

Cammeray, New South Wales, 2062, Australia

___________________________

This email was sent by Gabrielle Duigu via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Gabrielle provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Gabrielle Duigu at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 262 of 1149

Page 263: Wednesday, 08 July 2020 – 15:32:00

Dunning, Caryn – Wednesday, 29 July 2020 – 18:17:56Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Caryn DunningSent 7/29/2020 6:17:56 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 263 of 1149

Page 264: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 264 of 1149

Page 265: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 265 of 1149

Page 266: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Caryn Dunning

Howard Springs, Northern Territory, 0835, Australia

___________________________

This email was sent by Caryn Dunning via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Caryn provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Caryn Dunning at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 266 of 1149

Page 267: Wednesday, 08 July 2020 – 15:32:00

Elliott, Ray – Monday, 27 July 2020 – 10:17:44Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Ray ElliottSent 7/27/2020 10:17:44 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 267 of 1149

Page 268: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 268 of 1149

Page 269: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 269 of 1149

Page 270: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Ray Elliott

Port Davis, South Australia, 5540, Australia

___________________________

This email was sent by Ray Elliott via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverRay provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Ray Elliott at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 270 of 1149

Page 271: Wednesday, 08 July 2020 – 15:32:00

Ellis, Guy – Friday, 31 July 2020 – 14:37:16Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Guy EllisSent 7/31/2020 2:37:16 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 271 of 1149

Page 272: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 272 of 1149

Page 273: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________This email was sent by Guy Ellis via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverGuy provided an email address (*************) which we included in the REPLY-TO field.

Page 273 of 1149

Page 274: Wednesday, 08 July 2020 – 15:32:00

Please reply to Guy Ellis at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 274 of 1149

Page 275: Wednesday, 08 July 2020 – 15:32:00

Ernst, Greg – Thursday, 23 July 2020 – 00:22:43Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Greg ErnstSent 7/23/2020 12:22:43 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 275 of 1149

Page 276: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 276 of 1149

Page 277: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 277 of 1149

Page 278: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Greg Ernst

White Rock, Queensland, 4868, Australia

___________________________

This email was sent by Greg Ernst via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverGreg provided an email address (*************) which we included in the REPLY-TOfield.

Please reply to Greg Ernst at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 278 of 1149

Page 279: Wednesday, 08 July 2020 – 15:32:00

Eschborn, Marcus – Tuesday, 21 July 2020 – 02:29:36Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Marcus EschbornSent 7/21/2020 2:29:36 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 279 of 1149

Page 280: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 280 of 1149

Page 281: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 281 of 1149

Page 282: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Marcus Eschborn via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Marcus provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Marcus Eschborn at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 282 of 1149

Page 283: Wednesday, 08 July 2020 – 15:32:00

Eyre, Ms – Friday, 24 July 2020 – 11:08:31Subject Objection to Imperial Oil and GasFrom Ms EyreSent 7/24/2020 11:08:31 AM

To the Department of Environment and Natural Resources,

I have just heard about the planned drilling in NT - and am devastated. Enough destruction ofthe environment has been done - Now is the time for improvement, growth of the naturalenvironment - not activities that enhance the potential harm and destruction. Please re-consider.

Hence, I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Page 283 of 1149

Page 284: Wednesday, 08 July 2020 – 15:32:00

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

Page 284 of 1149

Page 285: Wednesday, 08 July 2020 – 15:32:00

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

Page 285 of 1149

Page 286: Wednesday, 08 July 2020 – 15:32:00

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Ms Eyre

Dawesville, Western Australia, 6211, Australia

___________________________

This email was sent by Ms Eyre via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverMs provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Ms Eyre at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 286 of 1149

Page 287: Wednesday, 08 July 2020 – 15:32:00

Fahndrich, Annelise – Friday, 24 July 2020 – 08:08:14Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Annelise FahndrichSent 7/24/2020 8:08:14 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 287 of 1149

Page 288: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 288 of 1149

Page 289: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 289 of 1149

Page 290: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Annelise Fahndrich

___________________________

This email was sent by Annelise Fahndrich via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Annelise provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Annelise Fahndrich at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 290 of 1149

Page 291: Wednesday, 08 July 2020 – 15:32:00

Fisher, Jay – Thursday, 30 July 2020 – 15:26:56Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jay FisherSent 7/30/2020 3:26:56 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 291 of 1149

Page 292: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 292 of 1149

Page 293: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 293 of 1149

Page 294: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Jay Fisher via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverJay provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Jay Fisher at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 294 of 1149

Page 295: Wednesday, 08 July 2020 – 15:32:00

Fitzgibbon, Jenny – Thursday, 23 July 2020 – 11:15:00Subject Thank you for accepting my Objection to Imperial Oil and Gas wet season drilling

program EP 187From Jenny FitzgibbonSent 7/23/2020 11:15:00 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

It is a strong objection, placed with love for this planet and the species on it in my heart andmind.

My key concerns with this plan, besides that it is immoral and curses our children, mine andyours, are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Page 295 of 1149

Page 296: Wednesday, 08 July 2020 – 15:32:00

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

Page 296 of 1149

Page 297: Wednesday, 08 July 2020 – 15:32:00

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

Page 297 of 1149

Page 298: Wednesday, 08 July 2020 – 15:32:00

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jenny Fitzgibbon

North Maleny, Queensland, 4552, Australia

___________________________

This email was sent by Jenny Fitzgibbon via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Jenny provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Jenny Fitzgibbon at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 298 of 1149

Page 299: Wednesday, 08 July 2020 – 15:32:00

Flisk, Sandra – Monday, 20 July 2020 – 16:24:30Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Sandra FliskSent 7/20/2020 4:24:30 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 299 of 1149

Page 300: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 300 of 1149

Page 301: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 301 of 1149

Page 302: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Sandra Flisk

Woodwark, Queensland, 4802, Australia

___________________________

This email was sent by Sandra Flisk via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Sandra provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Sandra Flisk at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 302 of 1149

Page 303: Wednesday, 08 July 2020 – 15:32:00

Flook, Nicola – Tuesday, 21 July 2020 – 22:17:50Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Nicola FlookSent 7/21/2020 10:17:50 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 303 of 1149

Page 304: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 304 of 1149

Page 305: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 305 of 1149

Page 306: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Nicola Flook

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Nicola Flook via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Nicola provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Nicola Flook at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 306 of 1149

Page 307: Wednesday, 08 July 2020 – 15:32:00

Garcia, Adriana – Thursday, 30 July 2020 – 17:33:33Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Adriana GarciaSent 7/30/2020 5:33:33 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 307 of 1149

Page 308: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 308 of 1149

Page 309: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 309 of 1149

Page 310: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Adriana Garcia

North Wollongong, New South Wales, 2500, Australia

___________________________

This email was sent by Adriana Garcia via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Adriana provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Adriana Garcia at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 310 of 1149

Page 311: Wednesday, 08 July 2020 – 15:32:00

Geake, Joel – Monday, 20 July 2020 – 17:56:35Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Joel GeakeSent 7/20/2020 5:56:35 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 311 of 1149

Page 312: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 312 of 1149

Page 313: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 313 of 1149

Page 314: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Joel Geake

Rochedale South, Queensland, 4123, Australia

___________________________

This email was sent by Joel Geake via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverJoel provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Joel Geake at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 314 of 1149

Page 315: Wednesday, 08 July 2020 – 15:32:00

Gohier, Franck – Monday, 27 July 2020 – 18:30:33Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Franck GohierSent 7/27/2020 6:30:33 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 315 of 1149

Page 316: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 316 of 1149

Page 317: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 317 of 1149

Page 318: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Franck Gohier

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Franck Gohier via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Franck provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Franck Gohier at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 318 of 1149

Page 319: Wednesday, 08 July 2020 – 15:32:00

Graham, Keith – Monday, 20 July 2020 – 13:30:30Subject Objection to Imperial Oil and Gas wet season drilling program EP 187 I’m have seen

fire coming out of the ground casing bushfires from fracking!! You just don’t know whatcould happen?

From Keith GrahamSent 7/20/2020 1:30:30 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

Page 319 of 1149

Page 320: Wednesday, 08 July 2020 – 15:32:00

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Page 320 of 1149

Page 321: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Page 321 of 1149

Page 322: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Keith Graham

Dumbalk North, Victoria, 3956, Australia

___________________________

This email was sent by Keith Graham via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Keith provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Keith Graham at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 322 of 1149

Page 323: Wednesday, 08 July 2020 – 15:32:00

Gwynne, Rozanne – Wednesday, 22 July 2020 – 19:14:21Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Rozanne GwynneSent 7/22/2020 7:14:21 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 323 of 1149

Page 324: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 324 of 1149

Page 325: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 325 of 1149

Page 326: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Rozanne Gwynne

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Rozanne Gwynne via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Rozanne provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Rozanne Gwynne at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 326 of 1149

Page 327: Wednesday, 08 July 2020 – 15:32:00

Hamiltons, Thomass – Monday, 20 July 2020 – 20:27:26Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Thomass HamiltonsSent 7/20/2020 8:27:26 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 327 of 1149

Page 328: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 328 of 1149

Page 329: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 329 of 1149

Page 330: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Thomass Hamiltons via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Thomass provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Thomass Hamiltons at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 330 of 1149

Page 331: Wednesday, 08 July 2020 – 15:32:00

Harge, Matt – Tuesday, 28 July 2020 – 10:07:54Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Matt HargeSent 7/28/2020 10:07:54 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 331 of 1149

Page 332: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 332 of 1149

Page 333: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Matt HargeLucas, Victoria, 3350, Australia

___________________________

Page 333 of 1149

Page 334: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Matt Harge via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Matt provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Matt Harge at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 334 of 1149

Page 335: Wednesday, 08 July 2020 – 15:32:00

Harris, Steve – Friday, 31 July 2020 – 16:01:23Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Steve HarrisSent 7/31/2020 4:01:23 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 335 of 1149

Page 336: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 336 of 1149

Page 337: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Steve HarrisAldinga, South Australia, 5173, Australia

___________________________

Page 337 of 1149

Page 338: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Steve Harris via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Steve provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Steve Harris at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 338 of 1149

Page 339: Wednesday, 08 July 2020 – 15:32:00

Harrison, Louise – Tuesday, 28 July 2020 – 16:55:08Subject Submission - Imperial Oil and Gas wet season drilling program EP 187From Louise HarrisonSent 7/28/2020 4:55:08 PM

Dear Department of Environment and Natural Resources,

Thank you for the opportunity to provide comment on the Revised EnvironmentalManagement Plan submitted by Imperial Oil and Gas for their 2020 Drilling Program NTExploration Permit (EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 339 of 1149

Page 340: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 340 of 1149

Page 341: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 341 of 1149

Page 342: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

L. Harrison

Darwin, Northern Territory, 0800, Australia

___________________________

This email was sent by Louise Harrison via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Louise provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Louise Harrison at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 342 of 1149

Page 343: Wednesday, 08 July 2020 – 15:32:00

Hauser, Greg – Monday, 20 July 2020 – 13:59:16Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Greg HauserSent 7/20/2020 1:59:16 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 343 of 1149

Page 344: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 344 of 1149

Page 345: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 345 of 1149

Page 346: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Greg Hauser

Mitchell, Northern Territory, 0832, Australia

___________________________

This email was sent by Greg Hauser via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Greg provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Greg Hauser at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 346 of 1149

Page 347: Wednesday, 08 July 2020 – 15:32:00

Hawthorne, Korina – Thursday, 30 July 2020 – 12:34:32Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Korina HawthorneSent 7/30/2020 12:34:32 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 347 of 1149

Page 348: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 348 of 1149

Page 349: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 349 of 1149

Page 350: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Korina Hawthorne

Humpty doo

0836 Northern territory

___________________________

This email was sent by Korina Hawthorne via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Korina provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Korina Hawthorne at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 350 of 1149

Page 351: Wednesday, 08 July 2020 – 15:32:00

HEADLAM, IAN – Thursday, 30 July 2020 – 20:08:10Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From IAN HEADLAMSent 7/30/2020 8:08:10 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 351 of 1149

Page 352: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 352 of 1149

Page 353: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 353 of 1149

Page 354: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

IAN HEADLAM

Queens Domain, Tasmania, 7000, Australia

___________________________

This email was sent by IAN HEADLAM via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however IAN provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to IAN HEADLAM at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 354 of 1149

Page 355: Wednesday, 08 July 2020 – 15:32:00

Heard, Shannon – Wednesday, 22 July 2020 – 07:46:37Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Shannon HeardSent 7/22/2020 7:46:37 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 355 of 1149

Page 356: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 356 of 1149

Page 357: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 357 of 1149

Page 358: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Shannon Heard

Tranmere, Tasmania, 7018, Australia

___________________________

This email was sent by Shannon Heard via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Shannon provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Shannon Heard at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 358 of 1149

Page 359: Wednesday, 08 July 2020 – 15:32:00

Helmore, Joel – Thursday, 30 July 2020 – 16:59:31Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Joel HelmoreSent 7/30/2020 4:59:31 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 359 of 1149

Page 360: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 360 of 1149

Page 361: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 361 of 1149

Page 362: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Joel Helmore

Darwin DC, Northern Territory, 0820, Australia

___________________________

This email was sent by Joel Helmore via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Joel provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Joel Helmore at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 362 of 1149

Page 363: Wednesday, 08 July 2020 – 15:32:00

Hepburn, Julie – Tuesday, 21 July 2020 – 20:58:32Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Julie HepburnSent 7/21/2020 8:58:32 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

There is no need for fracking. We should be investing time, energy, money and subsidies in torenewable energy based industries and employment

Also:

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Page 363 of 1149

Page 364: Wednesday, 08 July 2020 – 15:32:00

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

Page 364 of 1149

Page 365: Wednesday, 08 July 2020 – 15:32:00

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

Page 365 of 1149

Page 366: Wednesday, 08 July 2020 – 15:32:00

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Julie Hepburn

Howard Springs, Northern Territory, 0835, Australia

___________________________

This email was sent by Julie Hepburn via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Julie provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Julie Hepburn at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 366 of 1149

Page 367: Wednesday, 08 July 2020 – 15:32:00

Heydon, Carl – Monday, 20 July 2020 – 13:09:54Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Carl HeydonSent 7/20/2020 1:09:54 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 367 of 1149

Page 368: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 368 of 1149

Page 369: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 369 of 1149

Page 370: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Carl Heydon

Booyong, New South Wales, 2480, Australia

___________________________

This email was sent by Carl Heydon via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Carl provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Carl Heydon at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 370 of 1149

Page 371: Wednesday, 08 July 2020 – 15:32:00

Higgins, Martina – Tuesday, 28 July 2020 – 10:15:22Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Martina (Tina) Bernardi HigginsSent 7/28/2020 10:15:22 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 371 of 1149

Page 372: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 372 of 1149

Page 373: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 373 of 1149

Page 374: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Martina (Tina) Higgins

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Martina (Tina) Bernardi Higgins via Do Gooder, a website that allowspeople to contact you regarding issues they consider important. In accordance with webprotocol RFC 3834 we have set the FROM field of this email to our generic no-reply addressat *************, however Martina (Tina) provided an email address (*************)which we included in the REPLY-TO field.

Please reply to Martina (Tina) Bernardi Higgins at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 374 of 1149

Page 375: Wednesday, 08 July 2020 – 15:32:00

Hodgson, Ian – Monday, 20 July 2020 – 22:10:08Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Ian HodgsonSent 7/20/2020 10:10:08 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 375 of 1149

Page 376: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 376 of 1149

Page 377: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 377 of 1149

Page 378: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Ian Hodgson

Pokolbin, New South Wales, 2320, Australia

___________________________

This email was sent by Ian Hodgson via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Ian provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Ian Hodgson at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 378 of 1149

Page 379: Wednesday, 08 July 2020 – 15:32:00

HODGSON, NAOMI – Monday, 20 July 2020 – 12:34:30Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From NAOMI HODGSONSent 7/20/2020 12:34:30 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 379 of 1149

Page 380: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 380 of 1149

Page 381: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 381 of 1149

Page 382: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

NAOMI HODGSON

___________________________

This email was sent by NAOMI HODGSON via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however NAOMI provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to NAOMI HODGSON at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 382 of 1149

Page 383: Wednesday, 08 July 2020 – 15:32:00

Holland, Noel – Wednesday, 22 July 2020 – 08:55:55Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Noel HollandSent 7/22/2020 8:55:55 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 383 of 1149

Page 384: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 384 of 1149

Page 385: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 385 of 1149

Page 386: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Noel Holland

Earlville, Queensland, 4870, Australia

___________________________

This email was sent by Noel Holland via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Noel provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Noel Holland at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 386 of 1149

Page 387: Wednesday, 08 July 2020 – 15:32:00

Hookham, Andrew – Wednesday, 29 July 2020 – 11:01:05Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Andrew HookhamSent 7/29/2020 11:01:05 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 387 of 1149

Page 388: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 388 of 1149

Page 389: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 389 of 1149

Page 390: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Andrew Hookham

___________________________

This email was sent by Andrew Hookham via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Andrew provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Andrew Hookham at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 390 of 1149

Page 391: Wednesday, 08 July 2020 – 15:32:00

Hooper, Helen – Friday, 24 July 2020 – 08:26:28Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Helen HooperSent 7/24/2020 8:26:28 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 391 of 1149

Page 392: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 392 of 1149

Page 393: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 393 of 1149

Page 394: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Helen Hooper

Annandale, New South Wales, 2038, Australia

___________________________

This email was sent by Helen Hooper via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Helen provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Helen Hooper at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 394 of 1149

Page 395: Wednesday, 08 July 2020 – 15:32:00

Hoosan, Gadrian – Thursday, 30 July 2020 – 17:08:55Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Gadrian HoosanSent 7/30/2020 5:08:55 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 395 of 1149

Page 396: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 396 of 1149

Page 397: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 397 of 1149

Page 398: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Gadrian Hoosan

Borroloola, Northern Territory, 0854, Australia

___________________________

This email was sent by Gadrian Hoosan via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Gadrian provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Gadrian Hoosan at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 398 of 1149

Page 399: Wednesday, 08 July 2020 – 15:32:00

Houghton, Donella – Tuesday, 21 July 2020 – 22:43:11Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Donella HoughtonSent 7/21/2020 10:43:11 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 399 of 1149

Page 400: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 400 of 1149

Page 401: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 401 of 1149

Page 402: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Donella Houghton via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Donella provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Donella Houghton at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 402 of 1149

Page 403: Wednesday, 08 July 2020 – 15:32:00

Hughes, Jennifer – Monday, 20 July 2020 – 12:48:47Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jennifer HughesSent 7/20/2020 12:48:47 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 403 of 1149

Page 404: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 404 of 1149

Page 405: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 405 of 1149

Page 406: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jennifer Hughes

New South Wales, 2850, Australia

___________________________

This email was sent by Jennifer Hughes via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Jennifer provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Jennifer Hughes at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 406 of 1149

Page 407: Wednesday, 08 July 2020 – 15:32:00

Hutchinson, Terry – Tuesday, 21 July 2020 – 15:33:11Subject EP187 submissionFrom Terry HutchinsonSent 7/21/2020 3:33:11 PM

Dear Department of Environment and NaturalI am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are that there is water flow from the north throughoutAustralia. We cannot allow private companies to poison the water table. This is not 1950 oreven 1980. In 2020 we know the devastating effects of tampering with water. Water is thelifeblood of this nation.My second concern is with the effects of these activities on the Birdlife of this area.Surely the Australian government can do better than allow this to happen. This is an electionissue!Other mining companies have taken advantage of COVID to desecrate ancient sites.Now this!

Other concerns are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

Page 407 of 1149

Page 408: Wednesday, 08 July 2020 – 15:32:00

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 408 of 1149

Page 409: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Page 409 of 1149

Page 410: Wednesday, 08 July 2020 – 15:32:00

Yours sincerely,Terry HutchinsonOxley, Queensland, 4075, Australia

Sent from my iPhone

Page 410 of 1149

Page 411: Wednesday, 08 July 2020 – 15:32:00

Hutton, Colin – Tuesday, 21 July 2020 – 23:17:09Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Colin HuttonSent 7/21/2020 11:17:09 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 411 of 1149

Page 412: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 412 of 1149

Page 413: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 413 of 1149

Page 414: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Colin Hutton

Bundagen, New South Wales, 2454, Australia

___________________________

This email was sent by Colin Hutton via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Colin provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Colin Hutton at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 414 of 1149

Page 415: Wednesday, 08 July 2020 – 15:32:00

Isis, Bindi – Saturday, 25 July 2020 – 22:02:26Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Bindi IsisSent 7/25/2020 10:02:26 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 415 of 1149

Page 416: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 416 of 1149

Page 417: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 417 of 1149

Page 418: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Bindi Isis

___________________________

This email was sent by Bindi Isis via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverBindi provided an email address (*************) which we included in the REPLY-TOfield.

Please reply to Bindi Isis at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 418 of 1149

Page 419: Wednesday, 08 July 2020 – 15:32:00

Jackson, Billie – Friday, 31 July 2020 – 14:43:35Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Billie JacksonSent 7/31/2020 2:43:35 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 419 of 1149

Page 420: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 420 of 1149

Page 421: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 421 of 1149

Page 422: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

billie jackson

Booyong, New South Wales, 2480, Australia

___________________________

This email was sent by billie jackson via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however billie provided an email address (*************) which we included in theREPLY-TO field.

Please reply to billie jackson at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 422 of 1149

Page 423: Wednesday, 08 July 2020 – 15:32:00

James, Owen – Monday, 20 July 2020 – 15:50:22Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Owen JamesSent 7/20/2020 3:50:22 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 423 of 1149

Page 424: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 424 of 1149

Page 425: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 425 of 1149

Page 426: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Owen James via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Owen provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Owen James at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 426 of 1149

Page 427: Wednesday, 08 July 2020 – 15:32:00

Jennaway, JeanLuc – Tuesday, 21 July 2020 – 07:40:32Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jean-Luc JennawaySent 7/21/2020 7:40:32 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 427 of 1149

Page 428: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 428 of 1149

Page 429: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 429 of 1149

Page 430: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jean-Luc Jennaway

South Australia, 5223, Australia

___________________________

This email was sent by Jean-Luc Jennaway via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Jean-Luc provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Jean-Luc Jennaway at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 430 of 1149

Page 431: Wednesday, 08 July 2020 – 15:32:00

Jones, Valmai – Friday, 24 July 2020 – 09:25:59Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Valmai JonesSent 7/24/2020 9:25:59 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 431 of 1149

Page 432: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 432 of 1149

Page 433: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 433 of 1149

Page 434: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Valmai Jones

Tennant Creek, Northern Territory, 0860, Australia

___________________________

This email was sent by Valmai Jones via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Valmai provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Valmai Jones at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 434 of 1149

Page 435: Wednesday, 08 July 2020 – 15:32:00

K, Zoe – Wednesday, 22 July 2020 – 17:50:03Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Zoe KSent 7/22/2020 5:50:03 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 435 of 1149

Page 436: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 436 of 1149

Page 437: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 437 of 1149

Page 438: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Zoe K

Emungalan, Northern Territory, 0850, Australia

___________________________

This email was sent by Zoe K via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverZoe provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Zoe K at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 438 of 1149

Page 439: Wednesday, 08 July 2020 – 15:32:00

Kable, Vicki – Friday, 24 July 2020 – 20:50:56Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Vicki KableSent 7/24/2020 8:50:56 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 439 of 1149

Page 440: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 440 of 1149

Page 441: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 441 of 1149

Page 442: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Vicki Kable via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Vicki provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Vicki Kable at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 442 of 1149

Page 443: Wednesday, 08 July 2020 – 15:32:00

Kaoustos, Gabrielle – Wednesday, 29 July 2020 – 17:51:07Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Gabrielle KaoustosSent 7/29/2020 5:51:07 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 443 of 1149

Page 444: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 444 of 1149

Page 445: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 445 of 1149

Page 446: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Gabrielle Kaoustos

___________________________

This email was sent by Gabrielle Kaoustos via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Gabrielle provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Gabrielle Kaoustos at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 446 of 1149

Page 447: Wednesday, 08 July 2020 – 15:32:00

Kehoe, Olivia – Friday, 31 July 2020 – 13:53:09Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Olivia KehoeSent 7/31/2020 1:53:09 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 447 of 1149

Page 448: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 448 of 1149

Page 449: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Olivia Kehoe

___________________________

Page 449 of 1149

Page 450: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Olivia Kehoe via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Olivia provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Olivia Kehoe at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 450 of 1149

Page 451: Wednesday, 08 July 2020 – 15:32:00

Kelly, John – Monday, 20 July 2020 – 11:30:05Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From John KellySent 7/20/2020 11:30:05 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 451 of 1149

Page 452: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 452 of 1149

Page 453: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 453 of 1149

Page 454: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

John Kelly

Shoal Point, Queensland, 4750, Australia

___________________________

This email was sent by John Kelly via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverJohn provided an email address (*************) which we included in the REPLY-TO field.

Please reply to John Kelly at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 454 of 1149

Page 455: Wednesday, 08 July 2020 – 15:32:00

Kent, Judyanne – Monday, 20 July 2020 – 19:35:44Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Judyanne KentSent 7/20/2020 7:35:44 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 455 of 1149

Page 456: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 456 of 1149

Page 457: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 457 of 1149

Page 458: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Judyanne Kent

Girraween, Northern Territory, 0836, Australia

___________________________

This email was sent by Judyanne Kent via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Judyanne provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Judyanne Kent at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 458 of 1149

Page 459: Wednesday, 08 July 2020 – 15:32:00

Kesteven, Sybil – Tuesday, 28 July 2020 – 13:12:41Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Sybil KestevenSent 7/28/2020 1:12:41 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

I have visited Borroloola and the surrounding area in recent years and am extremelyconcerned that fracking should be allowed to happen in that region. The McArthur River is soimportant to the indigenous community which is already impacted by mining.My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

Page 459 of 1149

Page 460: Wednesday, 08 July 2020 – 15:32:00

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental and

Page 460 of 1149

Page 461: Wednesday, 08 July 2020 – 15:32:00

Baseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Sybil KestevenBondi, New South Wales, 2026, Australia

Page 461 of 1149

Page 462: Wednesday, 08 July 2020 – 15:32:00

___________________________This email was sent by Sybil Kesteven via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Sybil provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Sybil Kesteven at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 462 of 1149

Page 463: Wednesday, 08 July 2020 – 15:32:00

King, Margaret – Thursday, 30 July 2020 – 17:42:12Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Margaret KingSent 7/30/2020 5:42:12 PM

Dear Department of Environment and Natural Resources,

Better options than gas:

Investing in energy creation in the local area through a range of sustainable efficient energyoptions such as biodigestors, solar, wind, pumped hydro, etc. Would be a far better optionthan approving more fossil fuel destruction.

Winding down fossil fuels and investing in jobs in the local areas and Australian farming andmining companies by creating food, energy and micro industry (micro factories ) in the localcommunity could play a vital part of future economic plans. Here are some actions we cantake;

I hope you will have a look at some of these ideas and seriously consider investing taxpayerfunded resources and dollars into supporting Australian owned farms, mines and local areasinto redirecting their operations into planting industrial hemp and developing a plant toproduct processing (biofuel, 3D Filament and 3D printer (microfactory) mirreco houses).

Given that we are one of the sunniest places on the planet, we now have an unprecedentedopportunity to take advantage of this free natural resource. All it takes us a change in mindsetand valuing what matters most Clean air, water and environment. These are essential to oursurvival and our current energy choices are not reflecting their importance.

If investors changed direction and government provided resources (defence forces, experts inthe field under employed) to introduce sustainable energy sources Biodigestors, composters,solar and wind generators. and water efficient practices to Australian owned farms and miningoperations and suburban areas. It would help people in all areas get back on their feet andreduce operating expenses.

Our current agricultural practices could do with a rethink. Industrial Hemp is a truly versatiletextile which has been used to produce and fuel an airplane stronger then steel, build houses,paper, clothes, 3D filament, a superconductor better than graphene and the seed is highlynutritious. 5 to 10 Macadamia nuts a day are good for the heart. Chia and linseed are proteinand nutrient rich.

Using regenerative farming practices reduces, water, fertilizer and pest control expense. Weshould be supplying our defence force and under employed resources to Australian ownedfarmers and mining operations to help them to change to regenerative farming practices andencouraging nutrient dense, water efficient multifunction plants (eg Hemp over cotton,maccas over almonds, chia and linseed over rice). Our defence force should be assisting indefence of our food.

Netherlands is the second biggest exporter of food in the world after the US , even thoughtthey are one if the smallest nations. This is because the grow everything in green houseswhich conserve nutrients, water and reduce pests. Solar powered

Page 463 of 1149

Page 464: Wednesday, 08 July 2020 – 15:32:00

Hydroponic, aquaponic, vertical superfood production systems should be provided by thegovernment to all Australian owned farm, mining operations and in suburbs. This is where Iwant my taxpayer dollars to go, what about you?

Check out The BZE million jobs plan launched on Monday (same day one of the largestfrackers in the US filed for bankruptcy).

https://bze.org.au/the-million-jobs-plan/

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 464 of 1149

Page 465: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 465 of 1149

Page 466: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 466 of 1149

Page 467: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Margaret King

Kenmore Hills, Queensland, 4069, Australia

___________________________

This email was sent by Margaret King via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Margaret provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Margaret King at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 467 of 1149

Page 468: Wednesday, 08 July 2020 – 15:32:00

King, Penny – Monday, 20 July 2020 – 16:50:18Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Penny KingSent 7/20/2020 4:50:18 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 468 of 1149

Page 469: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 469 of 1149

Page 470: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 470 of 1149

Page 471: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Penny King via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Penny provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Penny King at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 471 of 1149

Page 472: Wednesday, 08 July 2020 – 15:32:00

Kinsela, Leigh – Thursday, 30 July 2020 – 16:50:14Subject Urgent Objection to Imperial Oil and Gas drilling program EP 187**From Leigh KinselaSent 7/30/2020 4:50:14 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 472 of 1149

Page 473: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 473 of 1149

Page 474: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 474 of 1149

Page 475: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Leigh Kinsela

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Leigh Kinsela via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Leigh provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Leigh Kinsela at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 475 of 1149

Page 476: Wednesday, 08 July 2020 – 15:32:00

Knox, Robin – Tuesday, 28 July 2020 – 14:24:32Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Robin KnoxSent 7/28/2020 2:24:32 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

It is not worth sacrificing this land to make oil and gas production a reality in this area.Thereare a number of possible negative impacts to people and communities posed by Imperial’sdrilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 476 of 1149

Page 477: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 477 of 1149

Page 478: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Robin KnoxNightcliff, Northern Territory, 0810, Australia

___________________________

Page 478 of 1149

Page 479: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Robin Knox via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Robin provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Robin Knox at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 479 of 1149

Page 480: Wednesday, 08 July 2020 – 15:32:00

Koller, Claudia – Monday, 20 July 2020 – 20:22:48Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Claudia KollerSent 7/20/2020 8:22:48 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 480 of 1149

Page 481: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 481 of 1149

Page 482: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 482 of 1149

Page 483: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Claudia Koller via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Claudia provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Claudia Koller at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 483 of 1149

Page 484: Wednesday, 08 July 2020 – 15:32:00

Koser, Di – Tuesday, 28 July 2020 – 10:31:15Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Di KoserSent 7/28/2020 10:31:15 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

We have enough gas already developed to transition to a 100% Rebewable economy!!

The economics of fracking don't add up!

There is no social licence for fracking.

Carbon emissions from fracking cannot be offset!

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

Page 484 of 1149

Page 485: Wednesday, 08 July 2020 – 15:32:00

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

Page 485 of 1149

Page 486: Wednesday, 08 July 2020 – 15:32:00

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

Page 486 of 1149

Page 487: Wednesday, 08 July 2020 – 15:32:00

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Di Koser

___________________________

This email was sent by Di Koser via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverDi provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Di Koser at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 487 of 1149

Page 488: Wednesday, 08 July 2020 – 15:32:00

Kretser, Steve – Tuesday, 28 July 2020 – 12:07:41Subject N.T. the place to beFrom Steve De KretserSent 7/28/2020 12:07:41 PM

Dear ole mates at the Department of Environmental Destruction and Exploitation of NaturalResources,

I've lived in the NT since 1971, and intend to eventually die here. Its one of the least spoiled,cleanest, greenest and wildest places in the world. I'll try to keep it this way. I hope you willas well.

Politicians come and go, (remember Giles?...what a dickhead) but the air, water and soil areforever. I'd happily support drilling into a politician, but certainly DO NOT support anydrilling exploration by the fracking industry.

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

Page 488 of 1149

Page 489: Wednesday, 08 July 2020 – 15:32:00

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

Page 489 of 1149

Page 490: Wednesday, 08 July 2020 – 15:32:00

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

Page 490 of 1149

Page 491: Wednesday, 08 July 2020 – 15:32:00

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Steve de Kretser

___________________________

This email was sent by Steve de Kretser via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Steve provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Steve de Kretser at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 491 of 1149

Page 492: Wednesday, 08 July 2020 – 15:32:00

Kroes, Maria – Friday, 24 July 2020 – 09:46:15Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Maria KroesSent 7/24/2020 9:46:15 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 492 of 1149

Page 493: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 493 of 1149

Page 494: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 494 of 1149

Page 495: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Maria Kroes

Euromina, South Australia, 5454, Australia

___________________________

This email was sent by Maria Kroes via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Maria provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Maria Kroes at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 495 of 1149

Page 496: Wednesday, 08 July 2020 – 15:32:00

Ladkin, Sharon – Friday, 31 July 2020 – 16:40:34Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Sharon LadkinSent 7/31/2020 4:40:34 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 496 of 1149

Page 497: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 497 of 1149

Page 498: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 498 of 1149

Page 499: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Sharon Ladkin via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Sharon provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Sharon Ladkin at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 499 of 1149

Page 500: Wednesday, 08 July 2020 – 15:32:00

Lake, Vanessa – Thursday, 23 July 2020 – 07:47:51Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Vanessa LakeSent 7/23/2020 7:47:51 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 500 of 1149

Page 501: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 501 of 1149

Page 502: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 502 of 1149

Page 503: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Vanessa Lake

Skennars Head, New South Wales, 2478, Australia

___________________________

This email was sent by Vanessa Lake via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Vanessa provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Vanessa Lake at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 503 of 1149

Page 504: Wednesday, 08 July 2020 – 15:32:00

Lawrie, Bunna – Friday, 24 July 2020 – 09:02:13Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Bunna LawrieSent 7/24/2020 9:02:13 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 504 of 1149

Page 505: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 505 of 1149

Page 506: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 506 of 1149

Page 507: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Frederique Robert

Collingwood North, Victoria, 3066, Australia

___________________________

This email was sent by Bunna Lawrie via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Bunna provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Bunna Lawrie at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 507 of 1149

Page 508: Wednesday, 08 July 2020 – 15:32:00

Leah, Penny – Tuesday, 21 July 2020 – 20:59:11Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Penny LeahSent 7/21/2020 8:59:11 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 508 of 1149

Page 509: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 509 of 1149

Page 510: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 510 of 1149

Page 511: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Penny Leah

Wollogorang, New South Wales, 2581, Australia

___________________________

This email was sent by Penny Leah via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Penny provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Penny Leah at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 511 of 1149

Page 512: Wednesday, 08 July 2020 – 15:32:00

Ledger, Annie – Tuesday, 28 July 2020 – 10:37:06Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Annie LedgerSent 7/28/2020 10:37:06 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 512 of 1149

Page 513: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 513 of 1149

Page 514: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 514 of 1149

Page 515: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Annie Ledger

North Maleny, Queensland, 4552, Australia

___________________________

This email was sent by Annie Ledger via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Annie provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Annie Ledger at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 515 of 1149

Page 516: Wednesday, 08 July 2020 – 15:32:00

Ledgerwood, Jessica – Tuesday, 21 July 2020 – 21:10:46Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jessica LedgerwoodSent 7/21/2020 9:10:46 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 516 of 1149

Page 517: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 517 of 1149

Page 518: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 518 of 1149

Page 519: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jessica Ledgerwood

Hamilton DC, New South Wales, 2303, Australia

___________________________

This email was sent by Jessica Ledgerwood via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Jessica provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Jessica Ledgerwood at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 519 of 1149

Page 520: Wednesday, 08 July 2020 – 15:32:00

Lee, Am – Friday, 24 July 2020 – 18:22:36Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Am LeeSent 7/24/2020 6:22:36 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 520 of 1149

Page 521: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 521 of 1149

Page 522: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 522 of 1149

Page 523: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Am Lee

___________________________

This email was sent by Am Lee via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverAm provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Am Lee at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 523 of 1149

Page 524: Wednesday, 08 July 2020 – 15:32:00

Lewis, Jenny – Thursday, 30 July 2020 – 18:45:39Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jenny LewisSent 7/30/2020 6:45:39 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 524 of 1149

Page 525: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 525 of 1149

Page 526: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 526 of 1149

Page 527: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jenny Lewis

___________________________

This email was sent by Jenny Lewis via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Jenny provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Jenny Lewis at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 527 of 1149

Page 528: Wednesday, 08 July 2020 – 15:32:00

Lewis, Jerome – Monday, 20 July 2020 – 13:56:16Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jerome LewisSent 7/20/2020 1:56:16 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 528 of 1149

Page 529: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 529 of 1149

Page 530: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 530 of 1149

Page 531: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jerome Lewis

Skennars Head, New South Wales, 2478, Australia

___________________________

This email was sent by Jerome Lewis via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Jerome provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Jerome Lewis at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 531 of 1149

Page 532: Wednesday, 08 July 2020 – 15:32:00

Lieman, Tan – Wednesday, 22 July 2020 – 19:35:03Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Tan LiemanSent 7/22/2020 7:35:03 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 532 of 1149

Page 533: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 533 of 1149

Page 534: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 534 of 1149

Page 535: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Tan Lieman

___________________________

This email was sent by Tan Lieman via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Tan provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Tan Lieman at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 535 of 1149

Page 536: Wednesday, 08 July 2020 – 15:32:00

Lisle, Patsy – Monday, 20 July 2020 – 18:49:39Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Patsy LisleSent 7/20/2020 6:49:39 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 536 of 1149

Page 537: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 537 of 1149

Page 538: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 538 of 1149

Page 539: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Patsy Lisle

Mallacoota, Victoria, 3892, Australia

___________________________

This email was sent by Patsy Lisle via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverPatsy provided an email address (*************) which we included in the REPLY-TOfield.

Please reply to Patsy Lisle at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 539 of 1149

Page 540: Wednesday, 08 July 2020 – 15:32:00

Logan, Fiona – Friday, 31 July 2020 – 14:31:54Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Fiona LoganSent 7/31/2020 2:31:54 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 540 of 1149

Page 541: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 541 of 1149

Page 542: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 542 of 1149

Page 543: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Fiona Logan

Yours sincerely,

Fiona Logan

Howitt, Queensland, 4890, Australia

___________________________

This email was sent by Fiona Logan via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Fiona provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Fiona Logan at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 543 of 1149

Page 544: Wednesday, 08 July 2020 – 15:32:00

Lubow, Soo – Wednesday, 22 July 2020 – 16:12:14Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Soo LubowSent 7/22/2020 4:12:14 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 544 of 1149

Page 545: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 545 of 1149

Page 546: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 546 of 1149

Page 547: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Soo Lubow via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Soo provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Soo Lubow at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 547 of 1149

Page 548: Wednesday, 08 July 2020 – 15:32:00

Lucas, Beatrice – Thursday, 30 July 2020 – 18:28:50Subject i object to Imperial Oil and Gas wet season drilling program EP 187From Beatrice LucasSent 7/30/2020 6:28:50 PM

Dear Department of Environment and Natural Resources,

As a previous NT resident I am writing to express my objection to the Revised EnvironmentalManagement Plan submitted by Imperial Oil and Gas for their 2020 Drilling Program NTExploration Permit (EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 548 of 1149

Page 549: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 549 of 1149

Page 550: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 550 of 1149

Page 551: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Beatrice Lucas

Clifton Beach, Queensland, 4879, Australia

___________________________

This email was sent by Beatrice Lucas via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Beatrice provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Beatrice Lucas at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 551 of 1149

Page 552: Wednesday, 08 July 2020 – 15:32:00

Macmanus, Eileen – Friday, 31 July 2020 – 15:29:28Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Eileen MacmanusSent 7/31/2020 3:29:28 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 552 of 1149

Page 553: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 553 of 1149

Page 554: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 554 of 1149

Page 555: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Eileen MacManus

Bracken Ridge, Queensland, 4017, Australia

___________________________

This email was sent by Eileen MacManus via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Eileen provided an email address (*************n) which weincluded in the REPLY-TO field.

Please reply to Eileen MacManus at *************n.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 555 of 1149

Page 556: Wednesday, 08 July 2020 – 15:32:00

Marks, Jan – Monday, 20 July 2020 – 17:19:14Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jan MarksSent 7/20/2020 5:19:14 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 556 of 1149

Page 557: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 557 of 1149

Page 558: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 558 of 1149

Page 559: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jan Marks

___________________________

This email was sent by Jan Marks via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverJan provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Jan Marks at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 559 of 1149

Page 560: Wednesday, 08 July 2020 – 15:32:00

Marshall, Ruby – Monday, 20 July 2020 – 10:59:41Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Ruby MarshallSent 7/20/2020 10:59:41 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

I have outlined my key concerns with this plan below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts on people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 560 of 1149

Page 561: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 561 of 1149

Page 562: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 562 of 1149

Page 563: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

I am strongly opposed to this project and do no think it should go ahead.

Thank you for considering my concerns,

Yours sincerely,

Ruby Marshall

White Gums, Northern Territory, 0870, Australia

___________________________

This email was sent by Ruby Marshall via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Ruby provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Ruby Marshall at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 563 of 1149

Page 564: Wednesday, 08 July 2020 – 15:32:00

Martin, Jean – Friday, 24 July 2020 – 08:49:08Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jean MartinSent 7/24/2020 8:49:08 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 564 of 1149

Page 565: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 565 of 1149

Page 566: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 566 of 1149

Page 567: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Jean Claire Martin BFA (Hons1)

Former NT resident of 23yrs

Phd Candidate, Griffith University

*************

*********

___________________________

This email was sent by Jean Martin via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Jean provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Jean Martin at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 567 of 1149

Page 568: Wednesday, 08 July 2020 – 15:32:00

Matthews, Taylor – Friday, 24 July 2020 – 07:58:50Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Taylor MatthewsSent 7/24/2020 7:58:50 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 568 of 1149

Page 569: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 569 of 1149

Page 570: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 570 of 1149

Page 571: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Taylor Matthews

Mitchell, Northern Territory, 0832, Australia

___________________________

This email was sent by Taylor Matthews via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Taylor provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Taylor Matthews at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 571 of 1149

Page 572: Wednesday, 08 July 2020 – 15:32:00

Mayger, IngeLise – Thursday, 23 July 2020 – 23:10:39Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Inge-Lise MaygerSent 7/23/2020 11:10:39 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 572 of 1149

Page 573: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 573 of 1149

Page 574: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 574 of 1149

Page 575: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Inge-Lise Mayger

Darwin Northern Territory, 0810, Australia

___________________________

This email was sent by Inge-Lise Mayger via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Inge-Lise provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Inge-Lise Mayger at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 575 of 1149

Page 576: Wednesday, 08 July 2020 – 15:32:00

Mccarhty, Kevin – Monday, 20 July 2020 – 15:40:56Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Kevin MccarhtySent 7/20/2020 3:40:56 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 576 of 1149

Page 577: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 577 of 1149

Page 578: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Kevin McCarhtyMarrara, Northern Territory, 0812, Australia

___________________________

Page 578 of 1149

Page 579: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Kevin McCarhty via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Kevin provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Kevin McCarhty at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 579 of 1149

Page 580: Wednesday, 08 July 2020 – 15:32:00

Mccormack, Jenny – Wednesday, 22 July 2020 – 08:32:27Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jenny MccormackSent 7/22/2020 8:32:27 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 580 of 1149

Page 581: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 581 of 1149

Page 582: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,jenny McCormackDumbalk North, Victoria, 3956, Australia

___________________________

Page 582 of 1149

Page 583: Wednesday, 08 July 2020 – 15:32:00

This email was sent by jenny McCormack via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however jenny provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to jenny McCormack at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 583 of 1149

Page 584: Wednesday, 08 July 2020 – 15:32:00

Mcevoy, Andrew – Monday, 20 July 2020 – 22:05:39Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Andrew McevoySent 7/20/2020 10:05:39 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 584 of 1149

Page 585: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 585 of 1149

Page 586: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 586 of 1149

Page 587: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Andrew McEvoy

Driver, Northern Territory, 0830, Australia

___________________________

This email was sent by Andrew McEvoy via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Andrew provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Andrew McEvoy at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 587 of 1149

Page 588: Wednesday, 08 July 2020 – 15:32:00

Mcgugan, Stephen – Sunday, 26 July 2020 – 13:51:08Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Stephen McguganSent 7/26/2020 1:51:08 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 588 of 1149

Page 589: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 589 of 1149

Page 590: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 590 of 1149

Page 591: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Stephen McGugan

Marrara, Northern Territory, 0812, Australia

___________________________

This email was sent by Stephen McGugan via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Stephen provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Stephen McGugan at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 591 of 1149

Page 592: Wednesday, 08 July 2020 – 15:32:00

Mcintyre, Heather – Friday, 24 July 2020 – 19:27:05Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Heather McintyreSent 7/24/2020 7:27:05 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 592 of 1149

Page 593: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 593 of 1149

Page 594: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 594 of 1149

Page 595: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Heather McIntyre

East Side Northern Territory, 0870, Australia

___________________________

This email was sent by Heather McIntyre via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Heather provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Heather McIntyre at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 595 of 1149

Page 596: Wednesday, 08 July 2020 – 15:32:00

Meldrum, Garnet – Tuesday, 21 July 2020 – 14:07:11Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Garnet MeldrumSent 7/21/2020 2:07:11 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 596 of 1149

Page 597: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 597 of 1149

Page 598: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Garnet MeldrumEmungalan, Northern Territory, 0850, Australia

___________________________

Page 598 of 1149

Page 599: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Garnet Meldrum via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Garnet provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Garnet Meldrum at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 599 of 1149

Page 600: Wednesday, 08 July 2020 – 15:32:00

Melican, Maree – Tuesday, 28 July 2020 – 16:52:16Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Maree MelicanSent 7/28/2020 4:52:16 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 600 of 1149

Page 601: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 601 of 1149

Page 602: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 602 of 1149

Page 603: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Maree Melican

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Maree Melican via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Maree provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Maree Melican at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 603 of 1149

Page 604: Wednesday, 08 July 2020 – 15:32:00

Middleton, Sandie – Friday, 31 July 2020 – 15:30:41Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Sandie MiddletonSent 7/31/2020 3:30:41 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 604 of 1149

Page 605: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 605 of 1149

Page 606: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 606 of 1149

Page 607: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

sandie middleton

___________________________

This email was sent by sandie middleton via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however sandie provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to sandie middleton at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 607 of 1149

Page 608: Wednesday, 08 July 2020 – 15:32:00

Mills, Jeanette – Thursday, 30 July 2020 – 19:34:02Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jeanette MillsSent 7/30/2020 7:34:02 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 608 of 1149

Page 609: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 609 of 1149

Page 610: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 610 of 1149

Page 611: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jeanette Mills

Beerwah, Queensland, 4519, Australia

___________________________

This email was sent by Jeanette Mills via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Jeanette provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Jeanette Mills at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 611 of 1149

Page 612: Wednesday, 08 July 2020 – 15:32:00

Morgan, Dominique – Tuesday, 28 July 2020 – 11:37:26Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Dominique MorganSent 7/28/2020 11:37:26 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 612 of 1149

Page 613: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 613 of 1149

Page 614: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 614 of 1149

Page 615: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Dominique Morgan

Bucketty, New South Wales, 2250, Australia

___________________________

This email was sent by Dominique Morgan via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Dominique provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Dominique Morgan at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 615 of 1149

Page 616: Wednesday, 08 July 2020 – 15:32:00

Morison, Robert – Monday, 20 July 2020 – 14:47:57Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Robert MorisonSent 7/20/2020 2:47:57 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 616 of 1149

Page 617: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 617 of 1149

Page 618: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 618 of 1149

Page 619: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Robert Morison

Stanthorpe, Queensland, 4380, Australia

___________________________

This email was sent by Robert Morison via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Robert provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Robert Morison at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 619 of 1149

Page 620: Wednesday, 08 July 2020 – 15:32:00

MORONY, Amanda – Tuesday, 28 July 2020 – 11:54:07Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Amanda MORONYSent 7/28/2020 11:54:07 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 620 of 1149

Page 621: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 621 of 1149

Page 622: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 622 of 1149

Page 623: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Amanda MORONY

Woodville Park, South Australia, 5011, Australia

___________________________

This email was sent by Amanda MORONY via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Amanda provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Amanda MORONY at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 623 of 1149

Page 624: Wednesday, 08 July 2020 – 15:32:00

Morrigan, Viviane – Tuesday, 28 July 2020 – 14:07:30Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Viviane MorriganSent 7/28/2020 2:07:30 PM

Dear Department of Environment and Natural Resources,

I live in NSW and am concerned about worldwide environmental damage from globalwarming, and the Northern Territory government's contributory role if it continues to supportnon-renewable energy. Your decisions in this matter affect all Australians and beyond.

I wish to register my objection to the Revised Environmental Management Plan submitted byImperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit (EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

Page 624 of 1149

Page 625: Wednesday, 08 July 2020 – 15:32:00

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Page 625 of 1149

Page 626: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Page 626 of 1149

Page 627: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Viviane Morrigan

PO Box 168

Roselands, New South Wales, 2196, Australia

___________________________

This email was sent by Viviane Morrigan via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Viviane provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Viviane Morrigan at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 627 of 1149

Page 628: Wednesday, 08 July 2020 – 15:32:00

Morris, Steve – Thursday, 30 July 2020 – 16:05:37Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Steve MorrisSent 7/30/2020 4:05:37 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 628 of 1149

Page 629: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 629 of 1149

Page 630: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 630 of 1149

Page 631: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Steve Morris

Rum Jungle, Northern Territory, 0822, Australia

___________________________

This email was sent by Steve Morris via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Steve provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Steve Morris at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 631 of 1149

Page 632: Wednesday, 08 July 2020 – 15:32:00

Murphy, Dan – Monday, 20 July 2020 – 19:24:06Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Dan MurphySent 7/20/2020 7:24:06 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 632 of 1149

Page 633: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 633 of 1149

Page 634: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 634 of 1149

Page 635: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Dan Murphy

White Gums, Northern Territory, 0870, Australia

___________________________

This email was sent by Dan Murphy via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Dan provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Dan Murphy at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 635 of 1149

Page 636: Wednesday, 08 July 2020 – 15:32:00

Murray, Phillip – Friday, 24 July 2020 – 09:27:56Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Phillip MurraySent 7/24/2020 9:27:56 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 636 of 1149

Page 637: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 637 of 1149

Page 638: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 638 of 1149

Page 639: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Phillip Murray

Booyong, New South Wales, 2480, Australia

___________________________

This email was sent by Phillip Murray via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Phillip provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Phillip Murray at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 639 of 1149

Page 640: Wednesday, 08 July 2020 – 15:32:00

Murrin, Glenda – Monday, 20 July 2020 – 11:14:19Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Glenda MurrinSent 7/20/2020 11:14:19 AM

Let It Be Known

To the Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

Page 640 of 1149

Page 641: Wednesday, 08 July 2020 – 15:32:00

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Page 641 of 1149

Page 642: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Page 642 of 1149

Page 643: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Glenda Murrin

Gympie, Queensland, 4570, Australia

___________________________

This email was sent by Glenda Murrin via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Glenda provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Glenda Murrin at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 643 of 1149

Page 644: Wednesday, 08 July 2020 – 15:32:00

Newham, Dianna – Tuesday, 28 July 2020 – 20:25:18Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Dianna NewhamSent 7/28/2020 8:25:18 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

First and foremost, the Imperial's Revised EMP does not align with the principles ofecologically sustainable development, specifically the principle of inter-generational equity,intra-generational equity and the

polluter pays. The development of an onshore unconventional gas industry is inconsistentwith actions that are necessary to keep global climate change below 1.5oC. This EMP couldfacilitate the large-scale

development of the industry, thereby jeopardizing global mitigation efforts and compromisingthe health and stability of future generations.

Secondly, while the Scientific Inquiry Into Hydraulic Fracturing In The Northern Territorystated that risks could be reduced to an acceptable level, it also stated that there wasinsufficient information available to

make a fully informed decision about potential impact on groundwater resources. The RevisedEMP does not properly assess the risk by failing to acknowledge that uncertainty inknowledge.

I also have strong concerns about specific aspects of the EMP:

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

Page 644 of 1149

Page 645: Wednesday, 08 July 2020 – 15:32:00

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

Page 645 of 1149

Page 646: Wednesday, 08 July 2020 – 15:32:00

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on the

Page 646 of 1149

Page 647: Wednesday, 08 July 2020 – 15:32:00

Northern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Dianna Newham

Alice Springs, Northern Territory, 0870, Australia

___________________________

This email was sent by Dianna Newham via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Dianna provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Dianna Newham at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 647 of 1149

Page 648: Wednesday, 08 July 2020 – 15:32:00

Norman, Mark – Wednesday, 22 July 2020 – 08:17:12Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Mark NormanSent 7/22/2020 8:17:12 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 648 of 1149

Page 649: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 649 of 1149

Page 650: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 650 of 1149

Page 651: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Mark Norman

New South Wales, 2350, Australia

___________________________

This email was sent by Mark Norman via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Mark provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Mark Norman at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 651 of 1149

Page 652: Wednesday, 08 July 2020 – 15:32:00

Norrington, Leonie – Tuesday, 28 July 2020 – 10:12:24Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Leonie NorringtonSent 7/28/2020 10:12:24 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 652 of 1149

Page 653: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 653 of 1149

Page 654: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 654 of 1149

Page 655: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

leonie norrington

Manton, Northern Territory, 0837, Australia

___________________________

This email was sent by leonie norrington via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however leonie provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to leonie norrington at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 655 of 1149

Page 656: Wednesday, 08 July 2020 – 15:32:00

Norton, Naomi – Monday, 27 July 2020 – 22:07:46Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Naomi NortonSent 7/27/2020 10:07:46 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 656 of 1149

Page 657: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 657 of 1149

Page 658: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 658 of 1149

Page 659: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Naomi Norton

Mitchell, Northern Territory, 0832, Australia

___________________________

This email was sent by Naomi Norton via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Naomi provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Naomi Norton at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 659 of 1149

Page 660: Wednesday, 08 July 2020 – 15:32:00

Oakley, Jeny – Wednesday, 29 July 2020 – 08:42:23Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jeny OakleySent 7/29/2020 8:42:23 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 660 of 1149

Page 661: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 661 of 1149

Page 662: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 662 of 1149

Page 663: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jeny Oakley

Northwood, Victoria, 3660, Australia

___________________________

This email was sent by Jeny Oakley via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Jeny provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Jeny Oakley at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 663 of 1149

Page 664: Wednesday, 08 July 2020 – 15:32:00

Ocallaghan, Sue – Wednesday, 22 July 2020 – 13:50:58Subject Objection to Imperial Oil and Gas wet season drilling program EP 187 from Sue and

Max O'CallaghanFrom Sue And Max O'callaghanSent 7/22/2020 1:50:58 PM

Dear Department of Environment and Natural Resources,

We are writing to express our objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My husband Max was born in Alice Springs and I have lived here for 55 years. We attendedthe meeting in Alice Springs where the Draft Final Report of the Scientific Inquiry intoHydraulic Fracturing in the Northern Territory was presented. Although the conclusion wasthat fracking could be managed successfully if all recommendations were strictly adhered to,the overwhelming feeling from the panel and audience was that Government and Industrieswho wanted to be involved would never have the will or the finance to comply! The fact thatmany of the recommendations in the Report have been ignored by both the Government andImperial Oil and Gas means that the risks involved with fracking cannot be mitigated.

Clean water for drinking is our most valuable and necessary asset. Water for agriculture,cattle raising, manufacturing, cultural beliefs and recreation are also of prime importance. Inshort for LIFE!We in the Northern Territory simply cannot risk any venture that might threaten our preciousand limited reserve and supply of water. We already have evidence in the Katherine area andin other areas in the Territory and Australia of the problems caused by contaminated water.

Some more of our key concerns are:- chemicals used in the drilling process- storage of contaminated water in open pits and tanks- the disposal of waste materials- disturbance and destruction of sacred sites- disturbance and destruction of wildlife in the area - habitat,food supply, safety- destruction of our beautiful and unique country so important fortourism and the enjoyment of locals.

Thank you for your attention to our concerns. Please BAN fracking permanently in theNorthern Territory.

Yours sincerely,Sue and Max O'CallaghanAlice Springs, NT 0870

___________________________This email was sent by Sue and Max O'Callaghan via Do Gooder, a website that allowspeople to contact you regarding issues they consider important. In accordance with webprotocol RFC 3834 we have set the FROM field of this email to our generic no-reply addressat *************, however Sue and Max provided an email address (*************) whichwe included in the REPLY-TO field.

Page 664 of 1149

Page 665: Wednesday, 08 July 2020 – 15:32:00

Please reply to Sue and Max O'Callaghan at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 665 of 1149

Page 666: Wednesday, 08 July 2020 – 15:32:00

OdlingSmee, David – Monday, 20 July 2020 – 15:35:15Subject Please consider the negative impacts from the Imperial Oil and Gas drilling program EP

187From David Odling-SmeeSent 7/20/2020 3:35:15 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 666 of 1149

Page 667: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Page 667 of 1149

Page 668: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Page 668 of 1149

Page 669: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

David Odling-Smee

___________________________

This email was sent by David Odling-Smee via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however David provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to David Odling-Smee at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 669 of 1149

Page 670: Wednesday, 08 July 2020 – 15:32:00

Okeefe, Allan – Tuesday, 28 July 2020 – 18:55:39Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Allan O'keefeSent 7/28/2020 6:55:39 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 670 of 1149

Page 671: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 671 of 1149

Page 672: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 672 of 1149

Page 673: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Allan O'Keefe

___________________________

This email was sent by Allan O'Keefe via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Allan provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Allan O'Keefe at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 673 of 1149

Page 674: Wednesday, 08 July 2020 – 15:32:00

OKeefe, Susan – Tuesday, 28 July 2020 – 19:30:34Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Susan O’KeefeSent 7/28/2020 7:30:34 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 674 of 1149

Page 675: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 675 of 1149

Page 676: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 676 of 1149

Page 677: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Susan O’Keefe

Dundee Beach, Northern Territory, 0840, Australia

___________________________

This email was sent by Susan O’Keefe via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Susan provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Susan O’Keefe at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 677 of 1149

Page 678: Wednesday, 08 July 2020 – 15:32:00

OLoughlin, Nick – Thursday, 30 July 2020 – 19:03:12Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Nick O’LoughlinSent 7/30/2020 7:03:12 PM

Dear Department of Environment and Natural Resources,

There should be absolutely no drilling until the SREBA is completed.

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

Page 678 of 1149

Page 679: Wednesday, 08 July 2020 – 15:32:00

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Page 679 of 1149

Page 680: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Page 680 of 1149

Page 681: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Nick O’Loughlin

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Nick O’Loughlin via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Nick provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Nick O’Loughlin at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 681 of 1149

Page 682: Wednesday, 08 July 2020 – 15:32:00

Oneill, Les – Monday, 20 July 2020 – 12:20:26Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Les OneillSent 7/20/2020 12:20:26 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 682 of 1149

Page 683: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 683 of 1149

Page 684: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 684 of 1149

Page 685: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Les Oneill

Houtman Abrolhos, Western Australia, 6530, Australia

___________________________

This email was sent by Les Oneill via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverLes provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Les Oneill at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 685 of 1149

Page 686: Wednesday, 08 July 2020 – 15:32:00

Oomen, M – Tuesday, 21 July 2020 – 01:28:43Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From M OomenSent 7/21/2020 1:28:43 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 686 of 1149

Page 687: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 687 of 1149

Page 688: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 688 of 1149

Page 689: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by M Oomen via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverM provided an email address (*************) which we included in the REPLY-TO field.

Please reply to M Oomen at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 689 of 1149

Page 690: Wednesday, 08 July 2020 – 15:32:00

Oreilly, Rachel – Monday, 20 July 2020 – 23:01:20Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Rachel O'reillySent 7/20/2020 11:01:20 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 690 of 1149

Page 691: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 691 of 1149

Page 692: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 692 of 1149

Page 693: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Rachel O'Reilly via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Rachel provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Rachel O'Reilly at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 693 of 1149

Page 694: Wednesday, 08 July 2020 – 15:32:00

Osh, Harry – Tuesday, 28 July 2020 – 10:51:55Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Harry OshSent 7/28/2020 10:51:55 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 694 of 1149

Page 695: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 695 of 1149

Page 696: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 696 of 1149

Page 697: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Harald Osh

___________________________

This email was sent by Harry Osh via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverHarry provided an email address (*************) which we included in the REPLY-TOfield.

Please reply to Harry Osh at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 697 of 1149

Page 698: Wednesday, 08 July 2020 – 15:32:00

Owheel, Monica – Tuesday, 28 July 2020 – 15:17:41Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Monica O'wheelSent 7/28/2020 3:17:41 PM

Dear Department of Environment and Natural Resources,

As an Australian, I am writing to express my objection to the Revised EnvironmentalManagement Plan submitted by Imperial Oil and Gas for their 2020 Drilling Program NTExploration Permit (EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 698 of 1149

Page 699: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 699 of 1149

Page 700: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 700 of 1149

Page 701: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

CLIMATE CHANGE

I am also concerned about Climate Change and adding more fossil fuels into the economy andthe atmosphere. We don't want to lose our world in all its beauty with the extremes of weatherfrom the increased heat in the natural systems of water, atmosphere and sea.

Thank you for considering my concerns,

Yours sincerely,

Monica O'Wheel

Felixstow, South Australia, 5070, Australia

___________________________

This email was sent by Monica O'Wheel via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Monica provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Monica O'Wheel at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 701 of 1149

Page 702: Wednesday, 08 July 2020 – 15:32:00

Parrish, Ange – Tuesday, 28 July 2020 – 10:08:24Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Ange ParrishSent 7/28/2020 10:08:24 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 702 of 1149

Page 703: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 703 of 1149

Page 704: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 704 of 1149

Page 705: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

ange parrish

New South Wales, 2840 (temporary), Australia

___________________________

This email was sent by ange parrish via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however ange provided an email address (*************) which we included in the REPLY-TO field.

Please reply to ange parrish at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 705 of 1149

Page 706: Wednesday, 08 July 2020 – 15:32:00

Parsonson, Sharon – Friday, 24 July 2020 – 18:37:16Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Sharon ParsonsonSent 7/24/2020 6:37:16 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 706 of 1149

Page 707: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 707 of 1149

Page 708: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 708 of 1149

Page 709: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Sharon Parsonson via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Sharon provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Sharon Parsonson at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 709 of 1149

Page 710: Wednesday, 08 July 2020 – 15:32:00

Parsonson, Sharon – Tuesday, 28 July 2020 – 10:04:30Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Sharon ParsonsonSent 7/28/2020 10:04:30 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 710 of 1149

Page 711: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 711 of 1149

Page 712: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 712 of 1149

Page 713: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Sharon Parsonson

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Sharon Parsonson via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Sharon provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Sharon Parsonson at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 713 of 1149

Page 714: Wednesday, 08 July 2020 – 15:32:00

Peek, Dirk – Tuesday, 28 July 2020 – 12:28:54Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Dirk PeekSent 7/28/2020 12:28:54 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 714 of 1149

Page 715: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 715 of 1149

Page 716: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Dirk PeekNightcliff, Northern Territory, 0810, Australia

___________________________

Page 716 of 1149

Page 717: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Dirk Peek via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverDirk provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Dirk Peek at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 717 of 1149

Page 718: Wednesday, 08 July 2020 – 15:32:00

Perrot, Moana – Friday, 31 July 2020 – 16:08:14Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Moana PerrotSent 7/31/2020 4:08:14 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 718 of 1149

Page 719: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 719 of 1149

Page 720: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 720 of 1149

Page 721: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Moana Perrot via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Moana provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Moana Perrot at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 721 of 1149

Page 722: Wednesday, 08 July 2020 – 15:32:00

Phillips, Shane – Tuesday, 28 July 2020 – 14:24:48Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Shane PhillipsSent 7/28/2020 2:24:48 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 722 of 1149

Page 723: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 723 of 1149

Page 724: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 724 of 1149

Page 725: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Shane Phillips

Moulden, Northern Territory, 0830, Australia

___________________________

This email was sent by Shane Phillips via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Shane provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Shane Phillips at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 725 of 1149

Page 726: Wednesday, 08 July 2020 – 15:32:00

Pickering, Charlotte – Tuesday, 28 July 2020 – 10:36:56Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Charlotte PickeringSent 7/28/2020 10:36:56 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 726 of 1149

Page 727: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 727 of 1149

Page 728: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Charlotte PickeringKatherine, Northern Territory, 0851, Australia

___________________________

Page 728 of 1149

Page 729: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Charlotte Pickering via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Charlotte provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Charlotte Pickering at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 729 of 1149

Page 730: Wednesday, 08 July 2020 – 15:32:00

Pidcock, Christel – Monday, 20 July 2020 – 12:53:55Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Christel PidcockSent 7/20/2020 12:53:55 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 730 of 1149

Page 731: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 731 of 1149

Page 732: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 732 of 1149

Page 733: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Christel Pidcock

Charlton, Queensland, 4350, Australia

___________________________

This email was sent by Christel Pidcock via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Christel provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Christel Pidcock at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 733 of 1149

Page 734: Wednesday, 08 July 2020 – 15:32:00

Potter, Catherine – Thursday, 23 July 2020 – 11:21:51Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Catherine PotterSent 7/23/2020 11:21:51 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 734 of 1149

Page 735: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 735 of 1149

Page 736: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 736 of 1149

Page 737: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Catherine Potter

Agnes Water, Queensland, 4677, Australia

___________________________

This email was sent by Catherine Potter via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Catherine provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Catherine Potter at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 737 of 1149

Page 738: Wednesday, 08 July 2020 – 15:32:00

Powell, Danielle – Tuesday, 21 July 2020 – 08:52:13Subject Opposition to Imperial Oil and Gas drilling EP 187From Danielle PowellSent 7/21/2020 8:52:13 AM

Dear Department of Environment and Natural Resources,

I am writing to express my strong objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

Having just returned to my home in Alice Springs after an incredible trip through the TopEnd, I am now prompted to speak up. Where else in the world can we see such beauty andriches?

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, water

Page 738 of 1149

Page 739: Wednesday, 08 July 2020 – 15:32:00

and the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

Page 739 of 1149

Page 740: Wednesday, 08 July 2020 – 15:32:00

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

Page 740 of 1149

Page 741: Wednesday, 08 July 2020 – 15:32:00

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Danielle Powell

Alice Springs, Northern Territory, 0870, Australia

___________________________

This email was sent by Danielle Powell via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Danielle provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Danielle Powell at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 741 of 1149

Page 742: Wednesday, 08 July 2020 – 15:32:00

Price, Lesleyanne – Friday, 24 July 2020 – 10:09:45Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Lesleyanne PriceSent 7/24/2020 10:09:45 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 742 of 1149

Page 743: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 743 of 1149

Page 744: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 744 of 1149

Page 745: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

LesleyAnne Price

Moulden, Northern Territory, 0830, Australia

___________________________

This email was sent by LesleyAnne Price via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however LesleyAnne provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to LesleyAnne Price at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 745 of 1149

Page 746: Wednesday, 08 July 2020 – 15:32:00

RAY, ALLAN – Monday, 20 July 2020 – 13:00:06Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From ALLAN RAYSent 7/20/2020 1:00:06 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 746 of 1149

Page 747: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 747 of 1149

Page 748: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,ALLAN RAYBrunswick, Victoria, 3056, Australia

___________________________

Page 748 of 1149

Page 749: Wednesday, 08 July 2020 – 15:32:00

This email was sent by ALLAN RAY via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however ALLAN provided an email address (*************) which we included in theREPLY-TO field.

Please reply to ALLAN RAY at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 749 of 1149

Page 750: Wednesday, 08 July 2020 – 15:32:00

Rees, Annie – Tuesday, 28 July 2020 – 10:48:58Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Annie ReesSent 7/28/2020 10:48:58 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 750 of 1149

Page 751: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 751 of 1149

Page 752: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 752 of 1149

Page 753: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Annie Rees

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Annie Rees via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Annie provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Annie Rees at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 753 of 1149

Page 754: Wednesday, 08 July 2020 – 15:32:00

Reid, Melanie – Thursday, 30 July 2020 – 17:10:56Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Melanie ReidSent 7/30/2020 5:10:56 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 754 of 1149

Page 755: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 755 of 1149

Page 756: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________This email was sent by Melanie Reid via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,

Page 756 of 1149

Page 757: Wednesday, 08 July 2020 – 15:32:00

however Melanie provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Melanie Reid at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 757 of 1149

Page 758: Wednesday, 08 July 2020 – 15:32:00

Rhoades, Victoria – Tuesday, 21 July 2020 – 07:12:27Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Victoria RhoadesSent 7/21/2020 7:12:27 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 758 of 1149

Page 759: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 759 of 1149

Page 760: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 760 of 1149

Page 761: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Victoria Rhoades

___________________________

This email was sent by Victoria Rhoades via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Victoria provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Victoria Rhoades at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 761 of 1149

Page 762: Wednesday, 08 July 2020 – 15:32:00

Richardson, Ghar – Thursday, 30 July 2020 – 18:47:52Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Ghar RichardsonSent 7/30/2020 6:47:52 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is TOTALLY unacceptable that Imperial Oil and Gas would use open pits and unattendedopen-top tanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 762 of 1149

Page 763: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 763 of 1149

Page 764: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 764 of 1149

Page 765: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Ghar Richardson

___________________________

This email was sent by Ghar Richardson via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Ghar provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Ghar Richardson at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 765 of 1149

Page 766: Wednesday, 08 July 2020 – 15:32:00

Rickard, Diana – Tuesday, 21 July 2020 – 14:50:30Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Diana RickardSent 7/21/2020 2:50:30 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

I have lived and worked in the NT for nearly 50 years and it is in my blood. Our country isnot a quarry. It is unique and beautiful and I love it dearly.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not be

Page 766 of 1149

Page 767: Wednesday, 08 July 2020 – 15:32:00

open and accessible to birdlife at any time. So many of our native and migratory birds areendangered or close to extinction due to inappropriate development.

Our 'leaders' even blame birds and animals for spreading diseases but scientists have strongevidence that it's human impact on natural habitats responsible for this. And - what could bemore invasive than open mining pits and polluted water on our precious wildlife?

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

Page 767 of 1149

Page 768: Wednesday, 08 July 2020 – 15:32:00

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

I live in a rural area that relies on groundwater for drinking and other domestic purposes. Iunderstand what the people around the Imperial lease must be feeling.

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous. We've had too many cases of 'concrete cancer' in the Top End already for us totrust this form of production infrastructure for water protection.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities. When this is added to increased carbon pollution from intensive bushfires, theregoes our carbon abatement plans!

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on the

Page 768 of 1149

Page 769: Wednesday, 08 July 2020 – 15:32:00

Northern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed. We must have a writtenguarantee (along with a hefty bond) for Imperial to adequately rehabilitate all Countryaffected by its mining activities.

I would like to continue to enjoy the beauty and enthusiasm of the tropical environment of theNT without worrying about unbridled corporatism taking over and wilfully destroying all thatmakes the NT a great place to be. I need your healthy concerns to match mine for this tohappen.

Thank you for considering my concerns,

Yours sincerely,

Diana Rickard

Berry Springs, Northern Territory, 0838, Australia

___________________________

This email was sent by Diana Rickard via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Diana provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Diana Rickard at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 769 of 1149

Page 770: Wednesday, 08 July 2020 – 15:32:00

Riederer, Karin – Tuesday, 28 July 2020 – 10:23:52Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Karin RiedererSent 7/28/2020 10:23:52 AM

Dear Department of Environment and Natural Resources,

As a former resident of Borroloola (with family who reside there) and Alice Springs, NT, andan active volunteer with BirdLife Australia, I am writing to express my objection to theRevised Environmental Management Plan submitted by Imperial Oil and Gas for their 2020Drilling Program NT Exploration Permit (EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program, including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite Indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas,• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity ofthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmnorth-west of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 770 of 1149

Page 771: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater".

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure,• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste.

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 771 of 1149

Page 772: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials,• Drilling fluids which include toxic biocides,• Drilling cuttings which could include naturally occurring radioactive materials,• Completion, suspension and kill fluids.

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes”. This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes”. Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns, and please heed them.

Yours sincerelyKarin Riederer, former resident of Alice Springs and Borroloola, NT; currently of MaslinBeach, South Australia, 5170, Australia

___________________________

Page 772 of 1149

Page 773: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Karin Riederer via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Karin provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Karin Riederer at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 773 of 1149

Page 774: Wednesday, 08 July 2020 – 15:32:00

Ritchie, Therese – Wednesday, 22 July 2020 – 17:55:16Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Therese RitchieSent 7/22/2020 5:55:16 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 774 of 1149

Page 775: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 775 of 1149

Page 776: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 776 of 1149

Page 777: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Therese Ritchie

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Therese Ritchie via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Therese provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Therese Ritchie at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 777 of 1149

Page 778: Wednesday, 08 July 2020 – 15:32:00

Robert, Frederique – Friday, 24 July 2020 – 09:01:28Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Frederique RobertSent 7/24/2020 9:01:28 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 778 of 1149

Page 779: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 779 of 1149

Page 780: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 780 of 1149

Page 781: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Frederique Robert

Collingwood North, Victoria, 3066, Australia

___________________________

This email was sent by Frederique Robert via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Frederique provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Frederique Robert at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 781 of 1149

Page 782: Wednesday, 08 July 2020 – 15:32:00

Robertson, Tony – Monday, 20 July 2020 – 14:27:36Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Tony RobertsonSent 7/20/2020 2:27:36 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 782 of 1149

Page 783: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 783 of 1149

Page 784: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 784 of 1149

Page 785: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Tony Robertson

Smythes Creek, Victoria, 3351, Australia

___________________________

This email was sent by Tony Robertson via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Tony provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Tony Robertson at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 785 of 1149

Page 786: Wednesday, 08 July 2020 – 15:32:00

Robins, Crystal – Monday, 20 July 2020 – 10:12:53Subject TRM: Objection to Imperial Oil and Gas wet season drilling program EP 187From Crystal RobinsSent 7/20/2020 10:12:53 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 786 of 1149

Page 787: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 787 of 1149

Page 788: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 788 of 1149

Page 789: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Crystal Robins

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Crystal Robins via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Crystal provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Crystal Robins at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 789 of 1149

Page 790: Wednesday, 08 July 2020 – 15:32:00

Robins, Dan – Friday, 17 July 2020 – 18:01:50Subject TRM: Objection to Imperial Oil and Gas wet season drilling program EP 187From Dan RobinsSent 7/17/2020 6:01:50 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

* Increased potential for accidents and damage to infrastructure due to vehiclemovements,* Impact to onsite indigenous heritage site not previously identified,* Land biodiversity impact due to heavy machinery movements,* Increased intensity of flooding from land clearing and drilling activities,* Noise and vibration due to vehicles movements, civil works and drilling activities,* Light pollution due to artificial lighting required for safe operations,* Disturbance to heritage sites due to works conducted out of the approved areas.* Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 790 of 1149

Page 791: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters SearchToolidentified 13 threatened species that have the potential to occur in the Project Area. Ofthese, the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

It is anticipated that 2.5ML of water will be required for Imperial Oil and Gas’ drillingactivities.

A number of negative impacts to water are posed by Imperial’s drilling program including:

* Impact to groundwater quality and groundwater dependent ecosystems due to wellintegrity failure.* Impact to hydrological systems due to chemical spills, lack of appropriate bunding andpoor fuel, oil and chemical handling,* Contamination of water bodies due to storage (tank/vessels) failure,* Impact to surface water due to inappropriate management of waste

Page 791 of 1149

Page 792: Wednesday, 08 July 2020 – 15:32:00

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria. The Glyde is the maintributary to the McArthur River and lies to the east of the study area.

The Chambers River Formation and Cambrian Limestone provide regional scale aquifers forgroundwater resources available for pastoral enterprises, domestic bores at homesteads andtown water supplies several remote communities across the region.

Among the various formations to be intersected during drilling, the Gum Ridge Aquifer isexpected to be encountered at an approximate depth of *********m.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However it is well known that cement will crack overtime and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessmentrecommended in Section 7.4.3 of the Pepper Inquiry seeks to address thisknowledge gap. The SREBA has still not been finalised. Until the SREBA is finalised thisdrilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admits that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

* Produced water which could include naturally occurring radioactive materials* Drilling fluids which include toxic biocides* Drilling cuttings which could include naturally occurring radioactive materials* Completion, suspension and kill fluids

A list of the potential chemicals in the drilling fluids include: Bentonite API Weightingagent/viscosifier Calcium Carbonate Weighting agent/Bridging agent Caustic Soda pHadjustment Citric Acid pH adjustment Glut 9 Biocide Magnesium Oxide Conditioningchemical PAC LV Fluid loss additive PHPA Encapsulation Potassium Carbonate Potassiumcarbonate Potassium Chloride (KCl) Inhibitor Salt Weighting agent SAPP (Sodium AcidPyrophosphate) Dispersant Soda Ash pH adjustment Sodium Bicarbonate pH adjustmentSodium Sulphite Oxygen scavenger TEA HT polymer stabiliser Thinpool Thinner XanthanGum Viscosity. These chemicals could have an impact on the quality of soil and water in thearea especially if the drilling cuttings are to be buried in-situ (on-site).

A number of these chemicals are listed as hazardous and potentially hazardous and could posea contamination threat to soil, surface water and groundwater.

IMPACTS TO AIR QUALITY

Page 792 of 1149

Page 793: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas admits that “In the event of produced gas, flaring rather than ventingwill be implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed at a licenced facility. Thisuse of evaporation also poses a real risk to air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admits that “Inthe event of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns.

Dan Robins, Rapid Creek NT.

Page 793 of 1149

Page 794: Wednesday, 08 July 2020 – 15:32:00

Robins, Dan – Monday, 20 July 2020 – 09:05:46Subject TRM: Objection to Imperial Oil and Gas wet season drilling program EP 187From Dan RobinsSent 7/20/2020 9:05:46 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 794 of 1149

Page 795: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 795 of 1149

Page 796: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 796 of 1149

Page 797: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Dan Robins

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Dan Robins via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Dan provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Dan Robins at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 797 of 1149

Page 798: Wednesday, 08 July 2020 – 15:32:00

Robins, Dan – Tuesday, 28 July 2020 – 10:44:40Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Dan RobinsSent 7/28/2020 10:44:40 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 798 of 1149

Page 799: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 799 of 1149

Page 800: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 800 of 1149

Page 801: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Dan Robins

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Dan Robins via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Dan provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Dan Robins at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 801 of 1149

Page 802: Wednesday, 08 July 2020 – 15:32:00

Robins, Robbo – Tuesday, 21 July 2020 – 18:49:18Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Robbo RobinsSent 7/21/2020 6:49:18 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 802 of 1149

Page 803: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 803 of 1149

Page 804: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 804 of 1149

Page 805: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Ask the traditional owners if they want you to drill and frack thier land.

The answer will be no.

Thank you for considering my concerns,

Yours sincerely,

Robbo Rinins

Heathmere, Victoria, 3305, Australia

___________________________

This email was sent by Robbo Robins via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Robbo provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Robbo Robins at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 805 of 1149

Page 806: Wednesday, 08 July 2020 – 15:32:00

Rombouts, Maria – Monday, 20 July 2020 – 12:25:41Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Maria RomboutsSent 7/20/2020 12:25:41 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 806 of 1149

Page 807: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 807 of 1149

Page 808: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 808 of 1149

Page 809: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Maria Rombouts via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Maria provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Maria Rombouts at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 809 of 1149

Page 810: Wednesday, 08 July 2020 – 15:32:00

Ross, Trevor – Monday, 20 July 2020 – 19:56:25Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Trevor RossSent 7/20/2020 7:56:25 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 810 of 1149

Page 811: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 811 of 1149

Page 812: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 812 of 1149

Page 813: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Trevor Ross

Australia

___________________________

This email was sent by Trevor Ross via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Trevor provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Trevor Ross at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 813 of 1149

Page 814: Wednesday, 08 July 2020 – 15:32:00

Russell, Saffron – Tuesday, 28 July 2020 – 11:12:52Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Saffron RussellSent 7/28/2020 11:12:52 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 814 of 1149

Page 815: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 815 of 1149

Page 816: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 816 of 1149

Page 817: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Saffron Russell

Araluen, Northern Territory, 0870, Australia

___________________________

This email was sent by Saffron Russell via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Saffron provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Saffron Russell at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 817 of 1149

Page 818: Wednesday, 08 July 2020 – 15:32:00

Sagar, Colin – Monday, 20 July 2020 – 20:59:36Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Colin SagarSent 7/20/2020 8:59:36 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 818 of 1149

Page 819: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 819 of 1149

Page 820: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 820 of 1149

Page 821: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

colin sagar

Wadbilliga, New South Wales, 2546, Australia

___________________________

This email was sent by colin sagar via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howevercolin provided an email address (*************) which we included in the REPLY-TOfield.

Please reply to colin sagar at *************.

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To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 821 of 1149

Page 822: Wednesday, 08 July 2020 – 15:32:00

Sangcap, Elizabeth – Tuesday, 28 July 2020 – 15:54:32Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Elizabeth SangcapSent 7/28/2020 3:54:32 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 822 of 1149

Page 823: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 823 of 1149

Page 824: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 824 of 1149

Page 825: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Elizabeth Sangcap

White Gums, Northern Territory, 0870, Australia

___________________________

This email was sent by Elizabeth Sangcap via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Elizabeth provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Elizabeth Sangcap at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 825 of 1149

Page 826: Wednesday, 08 July 2020 – 15:32:00

Sawyer, Graeme – Thursday, 30 July 2020 – 11:42:09Subject Comments re EMP attachedFrom Graeme SawyerSent 7/30/2020 11:42:09 AM

please see attached

Best regards,

Graeme SawyerCoordinatorProtect Country Alliance

Ph *********

************* <mailto:*************>

Attached Documents

Page 826 of 1149

Page 827: Wednesday, 08 July 2020 – 15:32:00

1

Re: Objection to EMP 187

Thank you for the opportunity to comment on the EMP for Imperial Oil and Gas 2020

Drilling Program EP 187.

Please find below a list of concerns and suggestions for improvements that are

necessary. I put forward that the EMP should be rejected by the Minister.

Chemical use is not transparent:

The water management plan is simplistic and ignores the likely problems and does

not acknowledge and explain the details of items like chemicals to be used. These

are supposed to be specifically listed. As an example on page 354 the words “minor

chemical additives are used”. There is no way of knowing what this means and it

could potentially include the use of biocides which carry safety warnings like H412 -

Harmful to aquatic life with long lasting effects, or R51/53 which means Toxic to

aquatic organisms, may cause long-term adverse effects in the aquatic environment.

The text “Treat fluid to avoid bacteria” on page 362 would indicate biocides are to be

used. The chemical list on page 349 “Appendix 12. List of Potential Chemicals in the

Drilling Fluids” does not give adequate details to allow analysis of potential risks from

active ingredients. Given the fact this lack of detail is specifically against the Pepper

Inquiry recommendations and is a constant problem reported by fracking inquiries

around the world, the EMP needs to be rejected until this significant shortcoming is

addressed.

The EMP should be returned for appropriate listing of all chemicals including active

constituents or it should be denied approval.

The EMP should also be returned to address issues relating to chemical use and water

risks as the current document on page 134 “Activities are not expected to impact on

the environmental factor”, the factor being considered is water and Stygofauna.

Given the high risks created by many of the chemicals used in fracking and the

repeated issues around the globe that illustrate this risk the pepper inquiry requires

clear listing of all chemicals and related processes. Item 6.3.6 “Chemicals

Used chemicals will be collected in approved containers, segregated and disposed of

by an approved transport provider to a licenced facility” is a woefully simplistic

glossing over of these issues and again raises questions as to whether the operator

Page 827 of 1149

Page 828: Wednesday, 08 July 2020 – 15:32:00

2

is trying to avoid the implications of this issue.

Wet season drilling and flowback treatment is inappropriate:

There are very significant risks associated with field operations in the wet season and

the Pepper inquiry was clear that these risks meant operations should be limited.

Since the NT government showed it was willing to ignore the essence of the

recommendations in order to pander to industry, such as allowing open storage tanks

for waste, we see an increasing push for operations to be allowed during the wet

season.

Flowback treatment as per page 73 is not appropriate as it breaches the intent of the

Pepper inquiry, doubly so in wet season periods.

Waste transport details not addressed:

We also note that the way of removing waste from the site is not specified other than

using a licensed operator. If this means the waste is to be transported to QLD for

disposal this is inappropriate as some possible destination sites are subject to legal

challenges and may introduce serious pollutants into other watersheds.

Risks to wildlife:

Coverage of water pits with 150 by 150 mesh as per page 126 is not appropriate as

small fauna will easily access the stored fluids and any chemicals. Generally the use

of the term “appropriately designed” gives no confidence when issues like 150mm

mesh is proposed when some of the access issues relate to small birds and other

biodiversity accessing the ponds. Clearly this is not being developed in good faith

with NT conditions and requirements in mind. Who is defining the term appropriate.

The EMP should be returned for specific details to be provided.

This is completely inappropriate and is a clear breach of the EPBC act, the provisions

relating to Ecologically Sustainable Development (ESD) and the precautionary

principle . The Samuels report1 clearly articulates the failures of Jurisdictions like the

NTG to enforce the EPBC act and its embedded principles. The NT Government

espouses the ESD principles as the guiding principles in its decision making in

relation to the processes around fracking yet it does not implement this.

1 Samuel, G 2020, Independent Review of the EPBC Act—Interim Report, Department of Agriculture, Water and the Environment, Canberra,

June. CC BY 4.0.

Page 828 of 1149

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3

Aboriginal people are expressing serious concerns:

There is a lot of concern amongst Indigenous representatives across the region and

the potential impacts of fracking on their culture and the local environment.

Inadequate consultation with Aboriginal people from the region impacted is one core

parts of this breach. Many people express that they do not feel that there has been a

genuine informed discussion with them in relation to these matters.

The Pepper Inquiry heard that the integrated nature of the elements of the

environment is one of the ways in which the fracking proposals conflict with

responsibilities for Country and breach the ESD principles and pose risks to the health

and mental health of the community. A clear example of this is the way that the No

Go zones and related exclusion principles do not take into account the catchment

and feeder areas of springs and other groundwater dependent ecosystems, ignoring

the integrated nature of the local environment and again breaching ESD principles.

Aboriginal people have a very sophisticated knowledge of the water systems.

Throughout consultations during the Fracking Inquiry and beyond, evidence has been

put that fracking and the risks to water, including the volume, flows and quality posed

by the fracking process are unacceptable. There is no social licence for these

activities.

A thorough scientific baseline assessment should be conducted first:

The EMP does not answer many concerns and some of these items cannot be

realistically assessed until the SREBA is completed. As an example, doing EDNA

sampling across the region before allowing any exploration would be a minimum first

step to identify Stygofauna and other risks associated with the water systems.

“An assessment of the possibility that groundwater biodiversity (stygofauna and

GDEs) may be affected by over extraction or contamination of groundwater can only

be done after the recommended SREBA is completed” (Pepper Inquiry p 166) 6.3.3 on

page 360.

There are a raft of questions relating to water systems and risks that do not appear

to be able to be answered by NTG and so the precautionary principle should apply.

As an example the plan shows that the high pressure high salinity Moroak aquifer is

to be penetrated during the drilling operation.

The ecology of the area should not be put at risk:

The EMP has inconsistencies which indicate inadequate consideration of important

Page 829 of 1149

Page 830: Wednesday, 08 July 2020 – 15:32:00

4

issues. As an example the document mentions there are patches of monsoon forest

scattered across the area particularly where there are permanent springs. It then goes

on to claim the exploration area has a low potential for Terrestrial Groundwater

Dependent Environments, yet they are not sure where they will actually drill the well.

This appears to be speculative and should not be allowed to proceed until much

greater clarity can be provided.

These statements are not compatible, as Monsoon Forest is groundwater dependent

and vitally important refuge sites for Biodiversity. The roles and types of refuges,

whether they are evolutionary or ecological refuges should be considered in more

detail and used as a part of the decision making process and possible no go zone

exclusions applied to monsoon forests and springs in such habitats.

The role of the refuge areas is critical for biodiversity2 in the semi-arid areas these

places are vital to the long term survival of species. The Plan is inadequate as it has

not given appropriate consideration to the issues and needs to address these issues

before any approval could be contemplated. This is especially the case when the

actual well location is uncertain.

Much of the area discussed is data deficient in relation to biodiversity and water

issues and these urgently need to be studied. In times of Biodiversity crisis it is not

appropriate for approvals to be given until these deficiencies can be met.

There are likely to be a number of species in the areas that have not been listed. The

habitats contain many of the features to support species that are found in other

locations of a similar nature. Some of these species such as Varanus Mitchelli and

species of land snails are endangered. It is not appropriate to dismiss these issues

because of significant data deficiencies in the records from the area.

The uncertainty of the drilling location means that an informed assessment cannot

be made in advance and Imperial must be made to revisit these issues once they have

determined the exact location. There is a strong likelihood that water removed from

the systems will impact on springs and flows.

Associated Water:

There are other claims in the EMP which are not supported by the facts and suggest

an attempt to ignore potentially important issues. One such example is that Imperial

claims there is no expectation of water being produced during drilling.

2 Davis, J., Pavlova A., Thompson, R., & Sunnucks, P., (2013) Evolutionary refugia and ecological

refuges: key concepts for conserving Australian arid zone freshwater biodiversity under climate

change, Global Change Biology 19 1970-1984

Page 830 of 1149

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5

“Due to well designs and the use of overbalanced drilling, water is not expected to

be produced during drilling. The potential for associated water to flow to surface

would be managed with the use of the overbalanced drilling fluid (water-based mud).”

This position may not be so black and white in reality, given the previous examples

of other wells in the region and the existence of high pressure systems such as the

Moroak underlying the area. As an example the log reports from Ronald 1 shows

water issues and extreme salinity of 118000 ppm. “The well did begin producing

water in the latter stages of drilling, requiring the water to be unloaded on each

connection”.

Further correspondence with the EPA and the fracking taskforce confirms a flowback

event at the Tanubirini well on August 23 2014.

In correspondence with Minister Lawler, the Minister acknowledged viii that the

departments responsible did not know the salinity or pressure in the Moroak, even

as she approved the drilling of wells through the system. Issues relating to the

implications of this Hypersaline system and its pressure need to be resolved before

allowing drilling to proceed through this system in the Mcarthur basin. The EMP must

be delayed until this matter is resolved.

Water risks due to corrosion:

There are enormous risks in association with well failure and the chemicals and their

short and long term risks. Well failures, corrosion , the pressure and salinity in the

Moroak sandstone layer and the associated heat and hypersalinity which are

corrosion risks but also risk mixing this saline layer with beneficial layers are all very

specific risks that need addressing.

With this Hypersaline and heated Moroak system being in contact with the well piping

there is a severe corrosion risk. When the pipes eventually fail the pressure in the

Moroak will push saltwater, chemicals and other pollutants into other areas of the

underground systems. There is potential for the hypersaline Moroak system to be

connected to the beneficial freshwater systems with devastating implications.

The issues of corrosive bacteria such as that noted 3 is of further concern and also

needs to be addressed. The proponent is using biocides because the corrosion

3https://web.archive.org/web/20190328182110/https:/www.einpresswire.com/article/480473562/xpandab

le-patches-to-extend-the-life-of-corroded-csg-wells-in-queensland-australia

Page 831 of 1149

Page 832: Wednesday, 08 July 2020 – 15:32:00

6

causing sulphide reducing bacteria are present. They have no capability to control

the bacteria on the outside of the well casing which will lead to corrosion like that

indicated in the SALTEL case (Footnote 3).

There is a high risk of these corrosive bacteria impacting on the concrete and steel

systems over time. The concrete provides food for these organisms and the by-

product of their activity is acid which dissolves concrete and corrodes steel, even

stainless alloys.

With hot hypersaline pressurised systems at depth causing corrosion risk and bacteria

causing corrosion at shallow depth in aquifers the precautionary principle within the

EPBC act and the ESD provisions of it, along with the ESD provisions in NT Government

fracking policies, requires that the EMP be stopped.

The EMP in its current form should be rejected:

In light of the less than adequate information, and the key components of the

hydraulic fracturing operations missing from this plan, we recommend the Minister

enacts the power of the Petroleum (Environment) Regulations Division 2 to request

more information and issue a resubmission notice for a full EMP by Imperial, or just

not approve the EMP.

The EMP is lacking in many areas and cannot be approved in its current form. This

is an obvious example of where the Pepper Inquiry highlighted the risks of the

deficiencies in data and knowledge about the biodiversity and water systems in the

region. The inquiry indicated that the SREBA was required to address this deficiency

but in the meantime, it is essential that the precautionary principle be applied and

caution taken with decision making. Some examples from the Pepper inquiry report

illustrate this issue of how significant knowledge gaps impeded “the ability to

properly assess the risks of any shale gas development.

The wastewater monitoring mentioned needs to be much more explicitly described

as there is no confidence that the operator has any intention or capacity of

implementing such a plan as outlined. Nor is there likely to be any monitoring of this

by the NT Government. it is inadequate to indicate that monitoring will occur and if

problems are found remediation deterrents will be implemented. Many of the

interactions with water could be nocturnal in the case of frogs or fleeting as in the

case of bird species.

The impacts of the chemicals may not be immediately obvious at the site or they may

cause more subtle impacts like infertility as indicated in some research about fracking

Page 832 of 1149

Page 833: Wednesday, 08 July 2020 – 15:32:00

7

activities in the US (E.g Pennsylvania Grand Jury report 2020). Items like “Wastewater

tanks do not contain tailing beaches or perches, reducing the ability for most birds

to land and drink from tanks” is simplistic and does not account for many bird species

which use dip bathing rather than perching. Further just below this item, still within

dot point 6.3.3 the item “Fauna ladders and/or bird islands will be installed at the

wastewater treatment tanks” is completely at odds with the previous item. Again the

simplistic nature of these responses indicates the operator is either not being serious

about the issues or is not able to address these issues. The EMP should be rejected

until these inadequacies and inconsistencies are addressed.

Yours truly,

Graeme Sawyer

Protect Country Alliance

Mobile 0411881378

Page 833 of 1149

Page 834: Wednesday, 08 July 2020 – 15:32:00

Sawyer, Nalani – Friday, 24 July 2020 – 17:02:30Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Nalani SawyerSent 7/24/2020 5:02:30 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 834 of 1149

Page 835: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 835 of 1149

Page 836: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 836 of 1149

Page 837: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Nalani Sawyer

Millner, Northern Territory, 0810, Australia

___________________________

This email was sent by Nalani Sawyer via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Nalani provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Nalani Sawyer at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 837 of 1149

Page 838: Wednesday, 08 July 2020 – 15:32:00

Schaffer, Maureen – Monday, 20 July 2020 – 11:14:28Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Maureen SchafferSent 7/20/2020 11:14:28 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 838 of 1149

Page 839: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 839 of 1149

Page 840: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 840 of 1149

Page 841: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Maureen Schaffer

Muirhead, Northern Territory, 0810, Australia

___________________________

This email was sent by Maureen Schaffer via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Maureen provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Maureen Schaffer at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 841 of 1149

Page 842: Wednesday, 08 July 2020 – 15:32:00

Schahinger, Dianne – Tuesday, 28 July 2020 – 15:37:01Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Dianne SchahingerSent 7/28/2020 3:37:01 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 842 of 1149

Page 843: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 843 of 1149

Page 844: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Dianne SchahingerChristie Downs, South Australia, 5164, Australia

___________________________

Page 844 of 1149

Page 845: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Dianne Schahinger via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Dianne provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Dianne Schahinger at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 845 of 1149

Page 846: Wednesday, 08 July 2020 – 15:32:00

Schlicht, Justine – Thursday, 30 July 2020 – 12:56:30Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Justine SchlichtSent 7/30/2020 12:56:30 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 846 of 1149

Page 847: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 847 of 1149

Page 848: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 848 of 1149

Page 849: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Justine Schlicht

___________________________

This email was sent by Justine Schlicht via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Justine provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Justine Schlicht at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 849 of 1149

Page 850: Wednesday, 08 July 2020 – 15:32:00

Schlunke, Elli – Friday, 24 July 2020 – 15:19:49Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Elli SchlunkeSent 7/24/2020 3:19:49 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 850 of 1149

Page 851: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 851 of 1149

Page 852: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 852 of 1149

Page 853: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Elli Schlunke

Obi Obi, Queensland, 4574, Australia

___________________________

This email was sent by Elli Schlunke via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Elli provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Elli Schlunke at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 853 of 1149

Page 854: Wednesday, 08 July 2020 – 15:32:00

Schultz, Kristy – Monday, 20 July 2020 – 19:35:18Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Kristy SchultzSent 7/20/2020 7:35:18 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 854 of 1149

Page 855: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 855 of 1149

Page 856: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 856 of 1149

Page 857: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Kristy Schultz

Marrara, Northern Territory, 0812, Australia

___________________________

This email was sent by Kristy Schultz via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Kristy provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Kristy Schultz at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 857 of 1149

Page 858: Wednesday, 08 July 2020 – 15:32:00

Schultz, Rosalie – Tuesday, 28 July 2020 – 18:52:09Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Rosalie SchultzSent 7/28/2020 6:52:09 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 858 of 1149

Page 859: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 859 of 1149

Page 860: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 860 of 1149

Page 861: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Rosalie Schultz

White Gums, Northern Territory, 0870, Australia

___________________________

This email was sent by Rosalie Schultz via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Rosalie provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Rosalie Schultz at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 861 of 1149

Page 862: Wednesday, 08 July 2020 – 15:32:00

Seymour, Frankie – Tuesday, 28 July 2020 – 10:15:50Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Frankie SeymourSent 7/28/2020 10:15:50 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 862 of 1149

Page 863: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 863 of 1149

Page 864: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Frankie SeymourNew South Wales, 2620, Australia

___________________________

Page 864 of 1149

Page 865: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Frankie Seymour via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Frankie provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Frankie Seymour at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 865 of 1149

Page 866: Wednesday, 08 July 2020 – 15:32:00

Shepherd, Louise – Tuesday, 21 July 2020 – 06:16:52Subject NO to fracking!From Louise ShepherdSent 7/21/2020 6:16:52 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 866 of 1149

Page 867: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 867 of 1149

Page 868: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 868 of 1149

Page 869: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Louise Shepherd

Flagstaff Hill, South Australia, 5159, Australia

___________________________

This email was sent by Louise Shepherd via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Louise provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Louise Shepherd at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 869 of 1149

Page 870: Wednesday, 08 July 2020 – 15:32:00

Sheridan, Teena – Tuesday, 28 July 2020 – 10:31:48Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Teena SheridanSent 7/28/2020 10:31:48 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 870 of 1149

Page 871: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 871 of 1149

Page 872: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 872 of 1149

Page 873: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

___________________________

This email was sent by Teena Sheridan via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Teena provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Teena Sheridan at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 873 of 1149

Page 874: Wednesday, 08 July 2020 – 15:32:00

Shields, Annette – Thursday, 30 July 2020 – 15:43:50Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Annette ShieldsSent 7/30/2020 3:43:50 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 874 of 1149

Page 875: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 875 of 1149

Page 876: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 876 of 1149

Page 877: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Annette Shields

Clontarf, Queensland, 4019, Australia

___________________________

This email was sent by Annette Shields via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Annette provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Annette Shields at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 877 of 1149

Page 878: Wednesday, 08 July 2020 – 15:32:00

Simons, Rob – Friday, 31 July 2020 – 16:56:24Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Rob SimonsSent 7/31/2020 4:56:24 PM

Dear Department of Environment and Natural Resources,

I have visited sites near Narribri and observed first hand the damage done by CSG drillingand can't imagine what will happen during a wet season in the NT.

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

Page 878 of 1149

Page 879: Wednesday, 08 July 2020 – 15:32:00

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Page 879 of 1149

Page 880: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Page 880 of 1149

Page 881: Wednesday, 08 July 2020 – 15:32:00

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Rob Simons

Guildford, Victoria, 3451, Australia

___________________________

This email was sent by Rob Simons via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Rob provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Rob Simons at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 881 of 1149

Page 882: Wednesday, 08 July 2020 – 15:32:00

SIRIANNI, Dianne – Thursday, 30 July 2020 – 16:36:08Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Dianne SIRIANNISent 7/30/2020 4:36:08 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 882 of 1149

Page 883: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 883 of 1149

Page 884: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Dianne SIRIANNI

___________________________

Page 884 of 1149

Page 885: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Dianne SIRIANNI via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Dianne provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Dianne SIRIANNI at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 885 of 1149

Page 886: Wednesday, 08 July 2020 – 15:32:00

Smith, Gayle – Thursday, 30 July 2020 – 19:09:19Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Gayle SmithSent 7/30/2020 7:09:19 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 886 of 1149

Page 887: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 887 of 1149

Page 888: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Gayle SmithNightcliff, Northern Territory, 0810, Australia

___________________________

Page 888 of 1149

Page 889: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Gayle Smith via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Gayle provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Gayle Smith at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 889 of 1149

Page 890: Wednesday, 08 July 2020 – 15:32:00

Smith, Jock – Friday, 24 July 2020 – 08:01:51Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Jock SmithSent 7/24/2020 8:01:51 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 890 of 1149

Page 891: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 891 of 1149

Page 892: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 892 of 1149

Page 893: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Jock Smith

Mount Byron, Queensland, 4312, Australia

___________________________

This email was sent by Jock Smith via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverJock provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Jock Smith at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 893 of 1149

Page 894: Wednesday, 08 July 2020 – 15:32:00

Smith, John – Thursday, 30 July 2020 – 17:23:38Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From John SmithSent 7/30/2020 5:23:38 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 894 of 1149

Page 895: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 895 of 1149

Page 896: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 896 of 1149

Page 897: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

John Smith

Guildford, Victoria, 3451, Australia

___________________________

This email was sent by John Smith via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however John provided an email address (*************) which we included in the REPLY-TO field.

Please reply to John Smith at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 897 of 1149

Page 898: Wednesday, 08 July 2020 – 15:32:00

Smith, Judy – Monday, 20 July 2020 – 12:43:14Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Judy SmithSent 7/20/2020 12:43:14 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 898 of 1149

Page 899: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 899 of 1149

Page 900: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 900 of 1149

Page 901: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Judy Smith

Thrumster, New South Wales, 2444, Australia

___________________________

This email was sent by Judy Smith via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Judy provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Judy Smith at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 901 of 1149

Page 902: Wednesday, 08 July 2020 – 15:32:00

Smith, Sherree – Friday, 31 July 2020 – 14:50:20Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Sherree SmithSent 7/31/2020 2:50:20 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 902 of 1149

Page 903: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 903 of 1149

Page 904: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 904 of 1149

Page 905: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Sherree Smith

Nightcliff, Northern Territory, 0810, Australia

___________________________

This email was sent by Sherree Smith via Do Gooder, a website that allows people to contactyou regarding issues they consider important. In accordance with web protocol RFC 3834 wehave set the FROM field of this email to our generic no-reply address at *************,however Sherree provided an email address (*************) which we included in theREPLY-TO field.

Please reply to Sherree Smith at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 905 of 1149

Page 906: Wednesday, 08 July 2020 – 15:32:00

Smith, Sue – Tuesday, 28 July 2020 – 10:36:08Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Sue SmithSent 7/28/2020 10:36:08 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,• Impact to onsite indigenous heritage site not previously identified,• Land biodiversity impact due to heavy machinery movements,• Increased intensity of flooding from land clearing and drilling activities,• Noise and vibration due to vehicles movements, civil works and drilling activities,• Light pollution due to artificial lighting required for safe operations,• Disturbance to heritage sites due to works conducted out of the approved areas.• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Not

Page 906 of 1149

Page 907: Wednesday, 08 July 2020 – 15:32:00

only could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,• Contamination of water bodies due to storage (tank/vessels) failure,• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallowaquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to address

Page 907 of 1149

Page 908: Wednesday, 08 July 2020 – 15:32:00

this knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials• Drilling fluids which include toxic biocides• Drilling cuttings which could include naturally occurring radioactive materials• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is notgood enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,Sue SmithNightcliff, Northern Territory, 0810, Australia

___________________________

Page 908 of 1149

Page 909: Wednesday, 08 July 2020 – 15:32:00

This email was sent by Sue Smith via Do Gooder, a website that allows people to contact youregarding issues they consider important. In accordance with web protocol RFC 3834 we haveset the FROM field of this email to our generic no-reply address at *************, howeverSue provided an email address (*************) which we included in the REPLY-TO field.

Please reply to Sue Smith at *************.

To learn more about Do Gooder visit www.dogooder.coTo learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 909 of 1149

Page 910: Wednesday, 08 July 2020 – 15:32:00

Sometimes, Beth – Tuesday, 21 July 2020 – 09:16:17Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Beth SometimesSent 7/21/2020 9:16:17 AM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 910 of 1149

Page 911: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 911 of 1149

Page 912: Wednesday, 08 July 2020 – 15:32:00

aquifers”. However, it is well known that cement will crack over time and this would bedisastrous.

There is insufficient information concerning Groundwater Dependent Ecosystems in theBeetaloo Sub-basin or elsewhere in the NT. The Strategic Regional Environmental andBaseline Assessment recommended in Section 7.4.3 of the Pepper Inquiry seeks to addressthis knowledge gap. The SREBA has still not been finalised. Until the SREBA is finalisedthis drilling program should not proceed.

CHEMICAL AND DRILLING FLUIDS TO BE USED

Imperial Oil and Gas admit that it’s wells are designed to be drilled utilising water-basedmuds and drilling fluids.

Drilling Activities will create a range of waste including:

• Produced water which could include naturally occurring radioactive materials

• Drilling fluids which include toxic biocides

• Drilling cuttings which could include naturally occurring radioactive materials

• Completion, suspension and kill fluids

IMPACTS TO AIR QUALITY

Imperial Oil and Gas admit that “In the event of produced gas, flaring rather than venting willbe implemented for emergency purposes.” This is a risk to the air quality of nearbycommunities.

Drilling fluids containing possible naturally occurring radioactive materials will beevaporated as much as possible; remaining fluid will be disposed of at a licenced facility. Thisuse of evaporation also poses a real risk to the air quality of nearby communities.

TRANSPORT RISKS AND TOURISM IMPACTS

Traffic management; specifically the management of unsealed access tracks during the wetseason increases the risks of accidents, erosion, spills and leaks. Furthermore, the increase intraffic movements potentially carrying toxic waste will have a negative impact on theNorthern Territory’s tourism sector that is already under stress from Covid 19. This isunacceptable.

BUSHFIRE RISKS DUE TO DRILLING ACTIVITIES

This area is sensitive to bushfires. Rural Fire Brigades have been calling for gas companies tostop ignition sources and flaring on total fire ban days. Imperial Oil and Gas admit that “In theevent of produced gas, flaring rather than venting will be implemented for emergencypurposes.” Imperial Oil and Gas must be made to stop all flaring on total fire ban days.

REHABILITATION CONSIDERATIONS

Imperial Oil and Gas has admitted in their revised EMP that they have “no specificconsiderations” for rehabilitation regarding the well site or access to well site. This is not

Page 912 of 1149

Page 913: Wednesday, 08 July 2020 – 15:32:00

good enough. Until Imperial Oil and Gas can prove to the community that they canrehabilitate these sites their drilling program should not proceed.

Thank you for considering my concerns,

Yours sincerely,

Beth Sometimes

___________________________

This email was sent by Beth Sometimes via Do Gooder, a website that allows people tocontact you regarding issues they consider important. In accordance with web protocol RFC3834 we have set the FROM field of this email to our generic no-reply address at*************, however Beth provided an email address (*************) which weincluded in the REPLY-TO field.

Please reply to Beth Sometimes at *************.

To learn more about Do Gooder visit www.dogooder.co

To learn more about web protocol RFC 3834 visit: https://tools.ietf.org/html/rfc3834

Page 913 of 1149

Page 914: Wednesday, 08 July 2020 – 15:32:00

Sorensen, Deb – Wednesday, 22 July 2020 – 19:02:11Subject Objection to Imperial Oil and Gas wet season drilling program EP 187From Deb SorensenSent 7/22/2020 7:02:11 PM

Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plansubmitted by Imperial Oil and Gas for their 2020 Drilling Program NT Exploration Permit(EP) 187.

My key concerns with this plan are outlined below.

IMPACTS TO PEOPLE AND COMMUNITIES

There are a number of possible negative impacts to people and communities posed byImperial’s drilling program including:

• Increased potential for accidents and damage to infrastructure due to vehicle movements,

• Impact to onsite indigenous heritage site not previously identified,

• Land biodiversity impact due to heavy machinery movements,

• Increased intensity of flooding from land clearing and drilling activities,

• Noise and vibration due to vehicles movements, civil works and drilling activities,

• Light pollution due to artificial lighting required for safe operations,

• Disturbance to heritage sites due to works conducted out of the approved areas.

• Road users, landholders discontent due to loss of visual amenity,

There are a number of pastoral properties with livestock and infrastructure in the vicinity orthe Tenement. The nearest property is OT Downs Homestead located approximately 20kmNorth-West of the proposed area.

USING OPEN PITS AND UNATTENDED OPEN-TOP TANKS IN THE WET SEASONPOSES AN UNACCEPTABLE RISK

It is unacceptable that Imperial Oil and Gas would use open pits and unattended open-toptanks in the wet season and risk the likelihood of overtopping.

These open pits are full of heavy metals, biocides and naturally occurring radioactivematerials.

Using open pits and unattended open-top tanks in the wet season poses a risk to soil, waterand the threatened birdlife that visits the site, including the Gouldian Finch, and should not beopen and accessible to birdlife at any time.

WET SEASON RISKS WITH WASTE ON SITE

Page 914 of 1149

Page 915: Wednesday, 08 July 2020 – 15:32:00

The summer monsoon season brings rain and cyclones and during this period the project areacan experience significant rainfall events.

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oiland Gas is planning to use open pits and unattended open-top tanks in the wet season. Notonly could this kill birds, but extreme weather events could cause downstream pollutionimpacts.

The Imperial Oil and Gas drilling program is at odds with the NT Fracking Inquiryrecommendation 7.12. The Inquiry stated that: “enclosed tanks must be used to hold allwastewater.”

DISPOSAL OF WASTE

Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling andtesting results drill cuttings will be buried and disposed in-situ (on site). This disposal ofpotentially hazardous waste on site is a threat to soil and water quality in the area.

If certification and DENR approval cannot be obtained for on-site disposal then this wastewill be disposed of to a licensed facility in Queensland. Residual drilling mud in the drillcuttings sump that does not evaporate and fails to meet disposal requirements as outlined inthe Code will be removed from site, before the onset of monsoon rains for disposal at alicensed facility in Queensland. This is not good enough, if this waste is too dangerous for theNT why should Queenslanders be forced to live with their toxic waste disposal?

THREATENED SPECIES IN THE AREA

There are 13 threatened species listed as potentially occurring within the project area, whichincludes a range of birds, mammals and reptiles.

The Environment Protection & Biodiversity Conservation Protected Matters Search Toolidentified 13 threatened species that have the potential to occur in the Project Area. Of these,the Gouldian Finch have a high potential to occur and Yellow-Spotted Monitor has amoderate likelihood of occurrence.

IMPACTS UPON GROUNDWATER AND SURFACE WATER

A number of negative impacts to water are posed by Imperial’s drilling program including:

• Impact to groundwater quality and groundwater dependent ecosystems due to well integrityfailure.

• Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poorfuel, oil and chemical handling,

• Contamination of water bodies due to storage (tank/vessels) failure,

• Impact to surface water due to inappropriate management of waste

The McArthur River is the primary surface water, water drain of the exploration area. Thiswater course drains the whole area into the Gulf of Carpentaria.

Imperial Oil and Gas state that they will use “a cemented production casing string to provideadditional protection barrier between producing hydrocarbon bearing zones and shallow

Page 915 of 1149

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