Environmental -...

Head Office Level 2, 23A Graham Street, Milton Queensland 4064 Australia | Phone: +61 7 3721 7500 | Fax: + 61 7 3721 7599 Email: [email protected] | Web: www.geodynamics.com.au | ABN 55 095 006 090 | Power from the Earth

Annual Report Licence Year 2, 10 May 2008 to 9 May 2009 Geothermal Retention Licences 3-12

Environmental

Document Number: ENV-RPT-001-1.0 Revision No: 1.0 Date: 1 October 2010

UNCONTROLLED WHEN PRINTED

of 42 ENV-RPT-001-1 0 GRL's 3-12 Annual Report 1 Oct 2010

CONTENTS

1. INTRODUCTION .......................................................................................................... 4

2. PERMIT SUMMARY ..................................................................................................... 4

3. REGULATED ACTIVITIES ........................................................................................... 5

3.1 Drilling ........................................................................................................................... 5

3.2 Well Operation Activities ............................................................................................... 5

3.3 Seismic Data Acquisition ............................................................................................... 6

3.4 Seismic Data Processing and Reprocessing ................................................................. 6

3.5 Geochemical, Gravity, Magnetic and other surveys ...................................................... 6

3.6 Pipeline/Flowline Construction and Operation ............................................................... 6

3.7 Preliminary Survey Activities ......................................................................................... 6

4. COMPLIANCE ISSUES ................................................................................................ 6

4.1 Licence and Regulatory Compliance ............................................................................. 6

4.2 Compliance with Statement of Environmental Objectives .............................................. 8

4.3 Management System Audits ......................................................................................... 8

4.4 Report and Data Submissions ....................................................................................... 9

4.5 Incidents ..................................................................................................................... 11

4.6 Treat Prevention ......................................................................................................... 11

4.7 Future Work Program .................................................................................................. 12

5. EXPENDITURE STATEMENT .................................................................................... 12

APPENDIX A GEODYNAMICS' COMPLIANCE FOR WATER EXTRACTION, PIPELINE CONSTRUCTION AND OPERATION ACTIVITIES ..................................................... 14

APPENDIX B GEODYNAMICS' COMPLIANCE FOR DIAGNOSTIC ACTIVITIES ....................... 17

APPENDIX C GEODYNAMICS' COMPLIANCE FOR DRILLING ACTIVITIES............................. 23

APPENDIX D GEODYNAMICS' COMPLIANCE FOR CONSTRUCTION AND OPERATION OF THE 1MW PILOT PLANT ................................................................................. 36



1. INTRODUCTION

Geothermal Retention Licences (GRL’s) 3 – 12 were granted to Geodynamics Limited on 10 May 2007 for a period of 5 years.

This report details the work conducted during Licence Year 2, of the licence (10 May 2008 to 9 May 2009) in accordance with Regulation 33 of the Petroleum Act 2000.

2. PERMIT SUMMARY

For the duration of the licence year, licensees for Geothermal Retention Licence (GRL’s 3-12) were:

Geodynamics Limited 70% (operator) Origin Energy Limited 30%

GRLs 3 - 12 have been granted without a set work programme (guaranteed or not guaranteed). The granting of these licences provides authorisation to Geodynamics to carry out operations (1) to establish the nature and extent of a discovery of geothermal energy, and (2) to establish the commercial feasibility of production and appropriate production techniques.

Licence Year 2 concluded on 9 May 2009. The following table (Table 2-1) displays the actual work completed up until the end of the current licence period.



Table 2-1: Work completed (as end of current reporting period) by licence year

Licence Year

Licence Dates Actual Work

Year 1 10/05/07 to 9/05/08 Drilling and flow testing well Habanero 3, construction of flow line between Habanero 3 and Habanero 1, and drilling well Jolokia 1.

Year 2 10/05/08 to 09/05/09 Completed drilling of Jolokia 1 Commenced drilling of Savina 1 Completed installation of Habanero closed loop pipeline. Carried out closed loop circulation testing of Habanero 3 to 1 closed loop. The Habanero pilot plant commenced construction and was nearing completion by the end of the period. Logs were run on Habanero 3, Jolokia 1 and Savina 1. Installation of the Jolokia acoustic monitoring network. Installation of the Savina acoustic monitoring network. Continuous acoustic monitoring was undertaken at the Habanero, Jolokia and Savina networks.

Year 3 10/05/09 to 09/05/10

Year 4 10/05/10 to 9/05/11

Year 5 10/05/11 to 9/05/12

3. REGULATED ACTIVITIES

3.1 Drilling

Habanero

No drilling activities were performed in the Habanero geothermal field.

Jolokia

Jolokia 1 was spudded on 18 March 2008 with a target depth of 4,300m. Its target depth was extended to 5,000m and the well reached a depth of 4,911m on 14 September 2008. It was suspended at this depth with rig release on 21 September 2008. The rig moved to the Savina location.

Savina

The Savina 1 well was spudded on 17 October 2008. After getting stuck at a depth of 3,700m on 8 January 2009 the well was suspended on 2 March 2009.

3.2 Well Operation Activities

Habanero

The construction of the closed loop pipeline between Habanero 1 and 3 was completed on 29 July 2008. However problems with the recirculation pump required repairs that extended through to



December 2008, including modifications to the pump in Singapore. The closed loop circulation test with chemical tracer injection commenced on 17 December 2008 after the pump performed satisfactorily for six days. The test was completed on 25 February 2009 with a pressure build-up test.

3.3 Seismic Data Acquisition

Nil.

3.4 Seismic Data Processing and Reprocessing

Nil.

3.5 Geochemical, Gravity, Magnetic and other surveys

Nil.

3.6 Pipeline/Flowline Construction and Operation

The closed loop flow line between Habanero 1 and Habanero 3 was completed and commissioned on 29 July 2008.

3.7 Preliminary Survey Activities

Nil.

4. COMPLIANCE ISSUES

4.1 Licence and Regulatory Compliance

Pursuant to Regulations 33(2) (b) & (c), an annual report must include:

“a report for the year on compliance with the Act, these regulations, the licence and any relevant statement of environmental objectives;” and

“a statement concerning any action to rectify non compliance with obligations imposed by the Act, these regulations or the licence, and to minimise the likelihood of recurrence of any such non-compliances.”

There were several instances during Year 2 of the GRL’s 3-12 in which Geodynamics failed to comply with the requirements of the licence, the Regulations of the Petroleum Act 2000 or the objectives of the SEO’s under which it conducted its field operations. Refer Table 2 below.

Licence Non-Compliance

There were no instances during Year 1 of the GRL 3-12 Licence in which Geodynamics failed to comply with the conditions of the Licence.

Regulatory Non-Compliance

There were several instances during the reporting year GRL 3-12 licence where Geodynamics failed to comply with the regulations of the Petroleum Act 2000. Refer Table 4-1.



Table 4-1: List of regulatory non-compliances for current reporting year

No. Date Activity Details of Non-Compliance

Rectification of Non-Compliance

1 9/05/09 Submission of annual report

Annual report not submitted in correct format and within time.

Report has been re-formatted in accordance with PIRSA's template. Delay in submission of hte Year 2 report was also affected by the time it took to close out the Year 1 report.

2 Various Provide copies of wireline logs to the Minister within 1 month of acquisition (Reg.n 39)

Failure to submit wire line logs in required time. Logs were not provided from a Habanero 3 image log and pressure-temperature-flow log. No logs were recorded in Jolokia 1 during the period. In total there were 19 logs that were run during the licence year of which 18 were due in the licence year and were all non compliant on submission requirements. Each log is listed individually in section 4.4.

The Company is implementing procedures to ensure compliance.

3 March 2009

Open flow test at Habanero

No approval applied for or received from PIRSA for this activity

Approval to be sought prior to this activity being undertaken in future.

4 Various Provide quarterly cased hole well activity report (Reg.n 41)

Quarterly cased hole reports not submitted.


5 26/5/08 An activity notification must be submitted for the Ministers approval at least 35 days before the proposed commencement.

Activity commenced without giving 35 notice - acoustic monitoring wells.

The Company has implemented procedures to ensure that activity Notifications are submitted in accordance with the regulations.

6 Various Downhole diagrams must be submitted within 2 after the installation or alteration of downhole equipment.

Downhole diagrams not submitted in accordance with regulations.


7 Various Well completion report must be submitted within 6 months after rig release

Well completion reports not submitted in accordance with regulations.




4.2 Compliance with Statement of Environmental Objectives

Activities carried out in GRL’s 3-12 during the Licence Year were undertaken under 4 different SEO’s as follows. A statement of performance against each of these SEO’s is provided in Appendices A-C.

Appendix No. Activity SEO Name

A Water extraction, pipeline construction and operation

Statement of Environmental Objectives Cooper Creek / Burley water hole water extraction & pipeline construction and operation. March 2003

B Diagnostics

Environmental Impact Report and Statement of Environmental Objectives Diagnostic Phase October 2004

C Drilling

South Australian Cooper Basin Operators Statement of Environmental Objectives: Drilling and Well Operations Santos 2003 Gazetted November 2003

D 1MW Pilot Plant Statement of Environmental Objectives 1MW Geothermal Power Plant August 2008

The following activities were carried out under the South Australian Cooper Basin Operators Statement of Environmental Objectives: Drilling and Well Operations

Drilling – Jolokia 1

Drilling – Savina 1

Hydraulic stimulation - Habanero 3

The Closed loop pipeline construction - Habanero 3 to Habanero 1, Open flow testing - Habanero 3, Circulation testing - Habanero 3 to Habanero 1, were carried out under the Habanero Circulation Diagnostic SEO, October 2004.

Abstraction of water from Cooper Creek and Burley Waterhole was carried out under the Cooper Creek / Burley Water Hole Extraction and Pipeline and Construction and Operation SEO, March 2003.

Construction and operation of the 1 MW Power plant was carried out under the Statement of Environmental Objectives 1MW Geothermal Power Plant, August 2008.

Compliance with the applicable SEO’s during the licence year is documented in Appendices A-D.

4.3 Management System Audits

Pursuant to Regulation 33(2) (d) under the Act, an annual report must include:



“a summary of any management system audits undertaken during the relevant licence year including information on any failure or deficiency identified by the audit and any corrective actions that has, or will be taken”.

During the licence year the following compliance audits were undertaken:

1. Drilling and well operations Environmental Audit – March 2009

This audit identified 2 non compliances with the relevant SEO (Drilling and Well Operations SEO, 2003). These non compliances related to:

Inadequate bunding of chemicals at Savina and Habanero; and Inappropriate storage of fuel, chemicals and other materials at Habanero 2

2. 1 MW Power Plant Environmental Audit – March 2009

This audit identified several non compliances with the relevant SEO (1 MW Power Plant, 2008). These non compliances related to:

Inadequate storage of fuel and visible soil contamination at Darby’s bore Unsustainable wastewater disposal from existing amenities at the Power Plant site Inadequate erosion and sediment control.

All of the audit findings have been addressed and closed out.

Copies of the full audit reports were provided to PIRSA in late March 2009.

4.4 Report and Data Submissions

Pursuant to Regulation 33(2) (e) under the Act, an annual report must include:

“a list of all reports and data relevant to the operation of the Act generated by the licensee during the licence year”.



Table 4-2: List of report and data submissions during current licence reporting year

Description of Report/Data Due Date Date Submitted

Compliant / Non-Compliant

Stimulation of well at Jolokia 1 - Activity Notification

At least 35 days prior to commencement of activity

3 July 2008 Compliant

Drilling of well at Savina 1 - Activity Notificaiton


15 July 2008 Compliant

1MW Visitor Centre and Power Plant Building - Activity Notification


1 August 2008

Compliant

Addendum to Operator Classification and Activity Notification for Innamincka visitors centre and 1MW Power Plant


7 August 2008

Compliant

Stimulation of well at Savina 1 - Activity Notification and Notices of Entry submitted. Approval received prior to commencement


5 February 2009

Compliant

Activity notification for the installation of 6 geophones


11 February 2009

Compliant

Activity Notification / Notices of Entry submitted for Jolokia 2


3 April 2009 Compliant

Quarterly cased hole reports for 2nd Quarter 2008

30 July 2008 14 September 2009

Non-compliant

Quarterly cased hole reports for 3rd Quarter 2008

30 October 2008 14 September 2009

Non-compliant

Quarterly cased hole reports for 4th Quarter 2008

30 January 2009 14 September 2009

Non-compliant

Quarterly cased hole reports for 1st Quarter 2009

30 April 2009 14 September 2009

Non-compliant

Quarterly cased hole reports for 2nd Quarter 2007

30 July 2007 14 September 2009

Non-compliant

Quarterly cased hole reports for 3rd Quarter 2007

30 October 2007 14 September 2009

Non-compliant

Quarterly cased hole reports for 4th Quarter 2007

30 January 2008 14 September 2009

Non-compliant

Jolokia 1 logs 18 June BHP-DSL-DAC-6Cal 17 August 2008

2 April 2009 Non-compliant



Jolokia 1 logs 15 Sept DSL-CN-ZDL-3Cal-ORIT-XMAC 14 November 2008


Jolokia 1 log 16 Sept SBT-CCL-GR-VDL 15 November 2008


Habanero 3 CBIL-DAC-Cal log 12.23 inch section 5 May 2008

8 August 2008

Non compliant from previous year

Savina 1 Cali-GR 14 January 2009

Submitted in 2009-2010

Non-compliant

4.5 Incidents

Pursuant to Regulation 33(2) (f), an annual report must include:

“in relation to any incidents reported to the Minister under the Act and these Regulations during the relevant licence year –

i. an overall assessment and analysis of the incidents, including the identification and analysis of any trends that have emerged; and

ii. an overall assessment of the effectiveness of any action taken to rectify non-compliance with obligations imposed by the Act, these regulations or the licence, or to minimise the risk of recurrence of any such non-compliance”.

There were 2 serious incidents, pursuant to section 83 of the Act and the relevant SEO during the licence year within GRLs 3-12.

On the evening of 24 April 2009 a well control incident occurred at Habanero 3 with uncontrolled flow of water and soon after steam from close to just below the well head. At the end of the reporting period on 9 May 2009, the flow had not been contained. Water from the well was flowing into a borrow pit located approximately 30m from the wellhead. The wall of the pit was raised to provided additional capacity if required.

At the end of the reporting Year (9 May 209) the well had not been brought under control. It was not until 21 May 2009 that the well was brought under control and Geodynamics has since conducted a thorough investigation of the root cause of the incident.

This incident is classified as a serious incident under section 85 of the Act and the relevant SEO. The investigation into the incident is still ongoing at the time, however an interim report was issued to PIRSA on 3 July 2009. The final incident report is expected to be issued in September 2009.

The second incident was also classified as serious and involved Geodynamics losing the bottom 1,006m of the drillstring in Savina 1. The string became stuck on 12 January 2009 and left in hole on 21 February 2009 with top at 2,738m which is above the Toolachee Formation. A cement plug above the fish left the Toolachee and the underlying Patchawarra Formation connected. These two formations are generally regarded as aquifers that need to be isolated from each other upon abandonment. However this condition may not apply in the Nappamerri Trough where 100 million years of high temperatures has destroyed formation permeability. The Patchawarra Formation was drilled considerably underbalanced (11.4 ppg) and did not contain any permeable sections. It could be argued that isolation of these two formations is unnecessary.

4.6 Treat Prevention

Pursuant to Regulation 33(2) (g) under the Act, an annual report must include:



“a report on any reasonably foreseeable threats (other than threats previously reported on) that reasonably presents, or may present, a hazard to facilities or activities under the licence, and a report on any corrective action that has, or will be taken”.

A number of HAZOP/HAZID workshops were carried out as part of the design process for the activities undertaken during the licence year.

Geodynamics Corporate H&S Policy was revised in April 2009. The Policy clearly enunciates the Company’s commitments in the areas of Health and Safety and control of hazards.

4.7 Future Work Program

Pursuant to Regulation 33(2) (h) under the Act, an annual report must include:

“unless the relevant licence year is the last year in which the licence is to remain in force – a statement outlining operations proposed for the ensuing year”.

The expected work program has been severely affected by the well control incident at Habanero 3 in April 2009. Until the cause of the incident has been completely determined the field activities are unclear. The expected emphasis of the work program is to develop the Jolokia reservoir as a second doublet (like Habanero 1 and 3 doublet) followed by a move back to the Savina well and create a third doublet. The Jolokia 1 well has an identical casing design to the Habanero 3 well so the design is likely to require some kind of protection. The Habanero power station is now not able to be brought into production until a new production well is drilled or Habanero 3 is remediated.

Given the likely time required to determine the completion needed for Jolokia 1 to overcome the Habanero 3 incident, it is unlikely that Jolokia 2 will be drilled in Licence Year 3 as originally expected. However the stimulation of Jolokia 1 following any remediation required is expected in the second half of the 2009-2010 reporting year. This stimulation will include the running of a high temperature image log, the first of its kind in the world with these hostile pressure and temperature conditions. The image log will require displacing the well with a clean fluid with high density and CaBr2 solution has been chosen for this operation.

The Jolokia 1 stimulation is being designed to be carried out in the deepest part of the well. Two separate stimulations will be attempted at two separate depths to create two reservoirs. Both reservoirs will be deeper and hotter than the reservoir created at Habanero in 2003 and extended in 2005.

In the following reporting year (2010-2011) Jolokia 2 will be drilled targeting the two reservoirs stimulated from Jolokia 1.

5. EXPENDITURE STATEMENT

Pursuant to Regulation 33(3) under the Act, an annual report must contain:

“An annual report must be accompanied by a statement of expenditure on regulated activities conducted under the licence for the relevant licence year, showing expenditure under each of the following headings:

(a) drilling activities;

(b) seismic activities;

(c) technical evaluation and analysis;

(d) other surveys;



(e) facility construction and modification;

(f) operating and administration expenses (not already covered under another heading)”.

Below is an expenditure statement for the current reporting period.

Expenditure Statement "Commercial in Confidence"

Drilling activities Seismic activities Technical evaluation and analysis Other surveys Facility construction and modification Operating and administration expenses TOTAL



Appendix A Geodynamics' compliance

for water extraction, pipeline construction and operation activities



Geodynamics compliance for water extraction, pipeline construction and operation activities.

SEO: Cooper Creek / Burley waterhole extraction & pipeline construction and operation

Environmental Objectives

Main sources of risk Assessment Criteria Assessment and Compliance Statement

1. Minimise impact of water harvesting downstream of Cooper Creek

Pumping too quickly from Cooper Creek

Pump water from Cooper Creek only when running at Innamincka causeway.

Pump at a maximum rate 16 1/sec over a maximum of 3 month period.

Maximum extraction from the Cooper Creek not to exceed 80 mega litres.

Communicate with community and NPWSA District Rangers, to identify potential issues and monitor compliance.

Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective. GDY employs full time field based supervisors to monitor and direct all field operations. As part of this position all field procedures are being reviewed to ensure ongoing compliance with the terms of this objective.

2. Minimise impact of water harvesting of Burley Water Hole

Extraction of significant amounts of water

Volume of water input into the water hole not to exceed 80 mega litres.

Volume of water remaining in the water hole at completion of extraction not to be less than 5 mega litres.

Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

3. Avoid disturbance to Aboriginal heritage sites

Access and pipeline construction

Site scouted and cleared by relevant groups; Any sites identified have been avoided; Recorders of scouting kept for auditing purposes

Heritage clearance undertaken prior to commencement of activities at Habanero 3 and Jolokia. Any sites identified have been avoided. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

4. Minimise disturbance to vegetation and habitat

Access and pipeline construction; natural limits on rehabilitation

Use of existing tracks and road access for stage 1 pipeline.

Use of four wheel drive light vehicle for construction of pipeline across dunes and gibber.

Use existing tracks and road during operations No multiple tracks created Liaise and consult with NPWSA District Ranger

regarding cross country vehicle access.

Existing tracks used and four wheel drives light vehicles. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

5. No fuel spills into Cooper Creek of

Minor spillage when refuelling generators

Precautions taken avoid any possible spills of fuel from tanks and pump entering the Cooper Creek and Burley

No spills of fuel.



Geodynamics compliance for water extraction, pipeline construction and operation activities.

SEO: Cooper Creek / Burley waterhole extraction & pipeline construction and operation

Environmental Objectives

Main sources of risk Assessment Criteria Assessment and Compliance Statement

Burley Water Hole water hole. Liaise and consult with NPWSA District Ranger

regarding location of pump and fuel tank locations.


6. Minimise soil impacts and disturbance to gibber surface

Erosion caused by access damage during construction and operations

Use Strzelecki track for access and laying of pipe Lay pipe on surface - no excavation activities No road or track construction No construction of tracks or other relevant work sites

along creek banks. Liaise and consult with NPSWA District Ranger

regarding cross country vehicle access.

Strezlecki track used for access and pipe laying. Pipe laid on surface No road or truck construction. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

7. Avoid disturbance to rare, endangered and vulnerable species

Disturbance caused by access and pipeline constructions and operations. Barrier to smaller fauna crossing pipeline.

No such species known to be present; avoid swamp areas and no removal of trees

No excavation or heavy equipment to be used Provide access over and under pipe at regular

intervals near water courses and floodplains to allow access under or over by small fauna

Disturbance caused by access and pipeline construction minimised. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

8. Minimise adverse impact by livestock

Over use or water hole by cattle

Ongoing monitoring and communication with pastoralists and relevant authorities

Ongoing monitoring and communication with pastoralists and relevant authorities. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

9. Avoid adverse impacts on tourists

Noise from pumps disturbing nearby campsite uses.

No tourist complaints regarding noise levels from pump Ongoing monitoring and communication with NPW

Rangers




Appendix B Geodynamics' compliance

for diagnostic activities



Geodynamics compliance for Diagnostic Activities

SEO: Environmental Impact Report and Statement of Environmental Objectives Dia

Objective Assessment Criteria Comment Assessment & Compliance Statement

1. Avoid disturbance to sites of Aboriginal heritage significance.

Any potential new access track required to be scouted before the commencement of construction

Any sites identified, have been flagged and subsequently avoided or removed by Claimants

Records of such scouting are kept and available for auditing

No new access tracks anticipated Heritage clearance survey carried out

on 2 May 2004 No heritage sites found within lease

area and adjacent clay plan One site at edge of clay pan was

recorded and flagged and subsequently moved by Claimants.

Compliance Statement: GDY to its knowledge believe it has complied with all obligated required under this SEO objective. GDY employs full time based supervisors to monitor and direct all field operations. As part of this position all field procedures are being reviewed to ensure ongoing compliance with the terms of this objective.

2. Minimise aquifer contamination and crossflow.

All aquifers in the sedimentary section isolated behind casing cemented to surface from the granite.

Chemical monitoring of water during test period in place.

Clay lined dam with impervious material to prevent seepages into aquifers

Seepage of dams and elevated chemical residual

Chemical monitoring documented

Well casing program has cased off aquifers from open hole section

Seismic analysis from Habanero #1 injection shows no indications of upward flow from granite to sedimentary rocks.

Short term diagnositc testing activity planned.

Clay material suitability to avoid tested and Geotechnical review of Construction specifications undertaken

Monitoring to be installed Automated and manual shut system

down in place.

All aquifers in the sedimentary section isolated. Compliance Statement: GDY was non-compliant with this objective during the licence year as open flow testing was conducted without appropriate notification and approval from PIRSA - Refer 4-1 above. In addition the dam that was used was note clay lined as required by this objective and objective 3.

3. Minimise impact of waste handling and disposal.

All rubbish removed leaving a clean, tidy and safe site after final cleanup

Sewage at camp disposed of in septic tank system at camp site.

Any toxic and hard waste to be removed from well site after completion and disposed of eventually at EPA-licensed waste disposal facility.

The attainment of this objective is assessed at the completion of the testing program to ensure that no rubbish is left on the site and is also assessed during the testing to ensure that sewage at the camp is disposed on in accordance to good-practice.

Clay lining material has been assessed for permeability, elasticity and desiccation.

All rubbish removed. Sewage at camp disposed of in septic tank system at camp site. Compliance Statement: GDY was non-compliant with this objective during the licence year as the dam that was used for water handling was not clay lined as required by this objective.






Containment of "produced water" into clay lined dam

Radioactive wastes above the limits defined by the Radiation Protection and Control Act (or equivalent) are to be disposed on according to EPA requirements.

Geotechnical review of construction / installation of clay lined material. Dam construction to be supervised.

4. Minimise disturbance to native vegetation and wildlife habitat.

Existing road, seismic lines and access track used, with new track rolled and not scraped.

Dams to be fenced Dams to provide bird deterrent

Activities predicted to have an insignificant impact on wildlife habitat mainly as a result of the small and confined land affected by such activities.

Short term diagnostic activity No removal whitewood scrub was

removed during the construction of Habanero #2 drill pad. These have been documented and removed in such a way that as many as possible will remain inside the lease fence.

Disturbance to vegetation minimised. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

5. Avoid Spills All refuelling of vehicles and

plant undertaken in clay floored and bunded designated areas.

Action plan similar to that undertaken at Habanero #1 and Habanero #2.

Refuelling of vehicles and plant undertaken in clay floored and bunded designated areas. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

6. In the event of a spill, minimise the impacts on fauna, flora, soil, gibber surface and ground water.

In the event of an diesel spill in a designated refuelling area; the spill is to be contained within the bunded area.

The stained soil allowed to naturally rehabilitate

In the event of a spill on gibber surfaces, spill was left to self-clean rather than risking

The main risk of an oil spill at this site relates to the diesel fuel stored and used in the drilling operation.

The risk of such a spill is considered low. However, in the case of an oil spill on soil in this environment it has been shown that bioremediation of the contaminated soil is an effective way for remediating the site to an







potentially serious consequences by disturbing the gibbers.

acceptable level which leaves no environmental adverse effect. The bioremediation process can be affective through natural processes, in particular for light oils such as diesel fuel, or through active remediation, where water and fertiliser is added to speed up the bioremediation process. In the case of a spill on a gibber plain, the severity of the potential erosion consequences associated with disturbing the gibbers to actively bioremediate the contaminated soil is considered too great to justify such active remediation. Instead, in this case, where diesel is the potential spill, it is best to leave the spill to bioremediate naturally.

7. Minimise impacts on soil.

Soil disturbance only confined to clay pan and installation of pipe work crossing Dillion Highway

Avoid soil inversion by stockpiling gibber/topsoil where applicable

In the event of any diesel spill in refuelling areas, the spilled to be contained within the bunded area.

Stained soil allowed to naturally rehabilitate.

Existing access track used, with new track rolled and not scraped.

The main impact on soil in relation to wells is the impact caused by the removal of existing soil and/or the importation of foreign material in the construction of the dams and installation of pipelines.

Insitu clay permeability testing adequate and to be used as first preference

There is little local plant species on clay pan

Pipeline installed above ground

Impacts to soil minimised. Compliance Statement: GDY to is knowledge believe it has complied with all obligations required under this SEO objective.

8. Minimise disturbance to gibber surfaces.

Existing access track used, with new track rolled and not

Activities on inter-dune area, not on gibber surface.

Compliance Statement: GDY to its knowledge believe it has complied with all obligations






scraped, other than where some large gibbers may have been moved where it is not practical or avoid.

required under this SEO objective.

9. Avoid the introduction of weed species.

All vehicles and equipment thoroughly cleaned prior to entering the region. Records of vehicle and equipment weed cleaning are kept and available for auditing.

The major potential source of weed introduction in relation to well activities is vehicles and equipment brought in from other regions of the state or interstate. In this case, any such incremental risk is considered as very low due to the use of other vehicles (eg. tourism) on the nearby Dillons Highway.

No vehicles from external areas are expected to be required during testing.

Introduction of weeds minimised. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

10. Minimise the visual impacts on the natural landscape.

Access track and well site rehabilitated to original contour to provide natural regeneration of local surrounding vegetation.

The major impact of sites and their access tracks is their visual impact, therefore consideration effort has gone into improving construction and restoration practices to minimise these impacts to as low as practicable.

Lease site and borrow pit are partly hidden from road by stands of trees and saplings.

Visual impacts minimised. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

11. Minimise safety hazards to third parties (including public)

Blow out prevention precautions in place with 10,000 psi Wellheads

Toxic and hard waste removed and disposed of off-site (eventually at EPA-licensed waste disposal facility)

Installed gas and steam monitors

Monitoring documented During operation - signage on

The location of dams has less impact on the general public than Habanero #1 because it is further from the Dillons Highway and partly obscured by trees.

Gases vented with steam Gas and Steam to be monitored with

automated and manual shut down in place.

Reduce Speed signs installed Request to be made to SA Transport to

reduce speed level nearby well sites.

Safety hazards minimised. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.






adjacent public road erected prohibiting public access and warning of danger from rig operations and regular truck movements.

12. Avoid adverse impacts on livestock

Danger areas are fenced off. Abandonment includes

backfilling to a level with the surrounding landscape

Main risks relate to injury from open sumps and well cellars, and proximity to moving equipment and machinery.

The site, and any dam constructed on the clay pan will be fully fenced.


13. Avoid potential sterilization of gas resources in the Cooper Basin during water flooding of the basement granite.

Ensure rock volume between injection zone and potential gas-bearing strata is adequate with respect to achieving this objective.

Casing and cementing pressure tested to 9000psi

Acoustic monitoring network detects no water flow upwards into sedimentary basin

Santos satisfied that safeguards have been set in agreement with Geodynamics.

Habanero #2 will only be stimulated as a contingency if initial circulation tests do not meet expectations. Seismic monitoring will be carried out during drilling of the granite and subsequent circulation and contingent stimulation. The seismic monitoring of Habanero #1 showed that the rock and stress conditions in the granite are not conducive to water flooding into the sedimentary levels and this is also an unlikely scenario in Habanero #2 and the circulation test is likely to be limited or non-existent.


14. Rehabilitation.

Goal assessment scaling (GAS) as detailed in Appendix 2-5 of the Statement of Environmental Objectives for Cooper Basin Drilling and Well Operations, SA (November 2003).

Rehabilitation has commenced, however, both Habanero #1 & Habanero #2 site are still in use.




Appendix C Geodynamics' compliance

for drilling activities



Geodynamics Compliance for Drilling Activities

SEO: South Australia Cooper Basin Operators Statement of Environmental Objectives: Drilling and Well Operations, Santos 2003

Environmental Objective

Comment Guide on How objectives can be achieved Assessment and Compliance

Statement

Objective 1: Minimise the risk to public and other third parties.

The criteria for assessing the achievement of this objective have been developed on the basis of the current understanding of the risks associated with drilling and well operations. The key to achieving this objective in relation to both downhole abandonment and surface well site restoration is to ensure that the visual prominence of the abandoned well site and its access track(s) is minimised to the extent where it is difficult for third parties to detect and therefore access these sites. The backfilling of the well cellar and the removal of rubbish from the restored site should be carried out. Fires or explosions at well sites could result in complications resulting in a spill of production fluids (formation water and hydrocarbon), atmospheric emissions, disturbance of native vegetation and wildlife habitat, loss of reservoir pressure, and risk to employees, contractors and the public. The movement of heavy equipment associated with rig moves present a risk to the safety of employees, contractors and third parties (ie. tourists).

All employees and contractor personnel complete a safety induction prior to commencement of work in the field.

All employees and contractor personnel undertake a refresher induction every 2 years.

Signage in place to warn third parties of access restrictions to operational areas, with particular warnings when potentially dangerous operations are being undertaken.

Permit to work systems in place for staff and contractors in dangerous situations.

All appropriate PPE (personal protective equipment) is issued and available as required in accordance with company operating requirements and applicable standards.

Effective Emergency Response Plan (ERP) and procedures are in place in the event of a fire or explosion.

Annual exercise of ERP. Communication of rig moves and other potential

hazards to safety associated with drilling and well operations to potentially affected parties prior to commencement of operations.

Reporting systems for recording injuries and accidents in place, and annual; (at minimum) review of records to determine injury trends. Implementation of appropriate corrective actions.

Ensuring safety management plans are updated and reviewed.

Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective. GDY employs full time field based supervisors to monitor and direct all field operations. As part of this position all field procedures are being reviewed to ensure ongoing compliance with the terms of this objective.

Objective 2: Minimise the disturbance and avoid contamination to

The impacts associated with soil disturbance can potentially include wind and water erosion and dust generation. The main source of disturbance to soils is associated with lease and access track construction, creation of

Well Site and Access Track Construction Consider alternate routes during planning phase to

minimise environmental impacts Gibber mantle on access tracks and well sites

Well Site and Access Track Construction 0, +1 or +2 GAS criteria are

attained for "Minimise visual impacts of abandoned well sites







Statement

soil. borrow pits, restoration activity, vehicle movement in off-road locations and sub-surface excavations (ie. sumps, flare pits and borrow pits).

(excluding sumps) has not been removed, only rolled, during construction and restoration on gibber and tableland land systems.

Topsoil stockpiled (including fibber mantle) from sump construction and respread on abandonment.

The need to traverse sensitive land systems and the methods of managing the impacts should be justified in accordance with company procedures, recorded and available for auditing.

Production Testing/Well Blowdowns If appropriate use:

Impermeable flare pit Flare tanks

Fuel and Chemical Storage and Handling All fuel, oil and chemical storages bunded in

accordance with the appropriate standards Records of spill events and corrective actions

maintained in accordance with company procedures

Spills or leads are immediately reported and clean up actions initiated

Logged incidents are reviewed annually to determine areas that may require corrective action in order to reduce spill volumes in subsequent years (and drive continual improvement)

Chemical and fuel storage procedures, including signage, are reviewed and monitored in audit process.

Spill Response / Contingency Planning Results of emergency response procedures

carried out in accord with Regulation 31 show that oil spill contingency plan in place in the event of a

and access tracks" objective as listed in Appendix 4 for well lease and access track construction.

No unauthorised off-road driving or creation of shortcuts.

No construction activities are carried out on salt lakes, steep tableland land systems or wetlands land systems (as defined in EIR)

Borrow pit construction and restoration 0, +1 or +2 GAS criteria are

attained for "Minimise Visual Impacts for constructing burrow pits" objective as listed in Appendix 3, and "Minimise visual impacts" and "Minimise impact on soil" objective as listed in Appendix 5.

Production Testing/Well Blowdowns Potential contamination of soil

has occurred as a result of the Habanero 3 Incident. Given that the well had not been brought under controlat the end of the Licence year, monitoring and investigation is ongoing and the need for remediation is yet to be determined.

Fuel and Chemical Storage and Handling

No spills/leaks outside of areas







Statement

spill in adequate and any necessary remedial action need to the plan in undertaken promptly.

Oil spill contingency plan (reviewed annually) is up to date with specific scenarios relating to spills to creeks and floodplain areas.

Spill response equipment is audited annually. Annual spill response training exercise in

undertaken.

Waste Disposal (domestic, sewage and sludges) Covered bins are provided for the collection of

storage and wastes. All loads of rubbish are covered during transport to

the central waste facility Pits are not established in locations, which pose

an unacceptable hazard to stock or wildlife.

designed to contain them. Level of hydrocarbon continually

decreasing for in situ remediation of spills.

Soils remediated to a level as determined by the SHI process.

Compliance Statement: GDY to its knowledge and through implementing the EIR requirements believe it has complied with all obligations required under this SEO objective. All domestic wastes are

disposed of in accordance with EPA requirements

0, +1 or +2 GAS criteria for domestic waste are attained

No spills or leaks from sewage treatment process.

Objective 3: Avoid the introduction of spread of pest plants and animals and implement control measures as necessary.

Activity associated with lease and access track construction, such as movement of vehicles and equipment, is a potential source of week or disease introduction and spread. The most effective technique to prevent the introduction and spreading of weed species is to ensure that vehicles and equipment are appropriately cleaned prior to entry into a construction site.

Where appropriate a weed and feral animal management strategy is in place (avoidance and control strategies).

Rig and vehicle wash downs are initiated in accordance with the management strategy.

No weeds or feral animals are introduced to operational areas. Compliance Statement: GDY to its knowledge and through implementing the EIR requirements believes that it has complied with all obligations under this SEO objective.

Objective 4: Minimise disturbance to drainage patterns and avoid contamination of

The main threats to drainage patterns and surface waters, and shallow ground waters are considered to be interruption of natural flows as a result of earthworks and contamination. Access track and well site selection should aim to minimise impact to drainage systems, by

Drilling Mud Sumps and Flare Pits All drill cuttings, muds and non-toxic drill fluids are

contained within the designated mud sumps with adequate freeboard at the completion of operations to allow to a 1m cover of clean fill at remediation.

Well Lease and Access Track Construction Well leases and access tracks

are located and constructed to maintain pre-existing water flows (ie. channel contours are







Statement

surface waters and shallow ground water resources.

avoiding sensitive areas and appropriate construction methods to avoid windrows. There is potential for the contamination of chemical and fuel storage areas, from oil and gas systems at well heads, during transportation of fuel and chemicals and during transportation of wastes. Localised contamination may result from spills or leaks of well operations chemicals (eg. corrosion inhibitors) during storage and handling. The major threat of spills is the threat to soil, vegetation and watercourses directly impacted by the spill. Therefore, the achievement of this objective also consequently contributes to the achievement of Objectives 2 and 7 in relation to minimising the impacts on soil and natural habitats. Avoidance of spills will be paramount in areas where the spill can be potentially spread beyond the immediate confines of the spill area into sensitive environments such as creeks and wetlands.

Well Heads (Oil and Gas Systems) Where appropriate, imperviously lined well cellars

are installed on oil wells. Chemical containment devices are installed on

gas well skids. Well heads shut in and chemicals removed prior to

flood events. Jet pumps are installed within containment device

with an adequately sized containment sump.

Well Blowdown/Production Testing Activity is conducted in accordance with accepted

industry standards / good oilfield practice. If appropriate use:

Impermeable flare pit Separators Supervision

Fuel and Chemical Storage and Handling All fuel, oil and chemical storages bunded in

accordance with the appropriate standards Records of spill events and corrective actions

maintained in accordance with company procedures

Spills or leaks are immediately reported and clean up actions initiated

Logged incidents are reviewed annually to determine areas that may require corrective action in order to reduce spill volumes in subsequent years (and drive continual improvement).

Chemical and fuel storage procedures, including signage, are reviewed and monitored in audit process.

maintained on floodplains and at creek crossings).

Drilling Mud Sumps and Flare Pits No overflow of drill cuttings,

muds and other drilling fluids from mud sumps.

No waste material disposal to sumps and flare pits.

Well Blowdown/Production Testing Potential contamination may

have occurred as a result of the Habanero 3 Incident. Given that the well had not been brought under control at the end of the licence year, monitoring and investigation is ongoing and the need for remediation is yet to be determined.

Fuel/Chemical Storage and Handling No leaks/spills outside of areas

designed to contain them.

Compliance Statement: There was a non compliance in terms of the uncontrolled flow to the surface from the Habanero 3 well. In addition the Savina incident where the Permian has been left open due to the drill pipe becoming stuck, resulting in non compliance.







Statement

Spill Response / Contingency Planning Results of emergency response procedures

carried out in accord with Regulation 31 show that oil spill contingency plan in place in the event of a spill is adequate and any necessary remedial action needed to the plan is undertaken promptly.

Oil spill contingency plan (reviewed annually) is up to date with specific scenarios relating to spills to creeks and floodplain areas.

Spill response equipment is audited annually. Annual spill response training exercise is

undertaken.







Statement

Objective 5: Avoid disturbance to sites of cultural and heritage significance.

The aim of the objective is to ensure that any sites of cultural (Aboriginal or non-Aboriginal) heritage significance are identified and protected.

Consultation with stakeholders (ie. Govenment agencies, landholders etc) in relation to the possible existence of heritage sites, as necessary.

Heritage report forms completed for any sites or artefacts identified, and report forms forward to the Department of Statement Aboriginal Affairs (DOSAA).

Survey records are kept and available for auditing. Areas requiring remediation which lie outside

previously surveyed sites should be surveyed in accordance with company heritage clearance procedures.

Note: Where a negotiated agreement or determination for heritage clearance is in place, compliance with the negotiated agreement or determination takes precedence over the above criteria.

Proposed well sites and access tracks have been surveyed and any sites of Aboriginal and non-Aboriginal heritage identified.

Any identified cultural and heritage sites have been avoided.

Compliance Statement: GDY to is knowledge and through implementing the EIR requirements believes that it has complied with all obligations required under this SEO objective.

Objective 6: Minimise loss of aquifer pressures and avoid aquifer contamination.

This objective seeks to protect the water quality and water pressure of aquifers that may potentially be useful as water supplies, and to maintain pressure in sands that may host petroleum accumulations elsewhere. To address this objective, the risks of cross flow between aquifer cells known to be permeable and in natural hydraulic isolation from each other, or where there is insufficient information to determine that they are permeable or in hydraulic communication, must be assessed on a case by case basis and procedures implemented to minimize the fresh water aquifer cells from contamination and isolate potential and producing formations from formulations that may deplete the reservoir pressure when not in production. The following geological formations are

Drilling & Completion Activities A competent cement bond between aquifer and

hydrocarbon reservoirs is demonstrated. For cases where isolation of these formations is not established, a risk assessment incorporating the use of pressure / permeability / salinity data is undertaken in consultation with DLWBC & AAWCMB to determine if lack of cement or poor bond will cause or has caused damaging crossflow which needs to be remediated.

Producing, Injection and Inactive Wells Monitoring programs implemented (eg. through

well logs, pressure measurements, casing integrity measurements and corrosion monitoring programs) to assess condition of casing and cross-flow behind casing.

Drilling & Completion Activities There was an uncontrolled flow

to surface (blow out) at Habanero 3. Refer to section 4.5 above.

Compliance Statement: There was a non compliance in terms of the uncontrolled flow to the surface from the Habanero 3 well. In addition the Savina incident where the Permian has been left open due to the drill pipe becoming stuck.







Statement

aquifers in the Cooper-Eromanga Basins. They may contain permeable sands which may be in natural hydraulic isolation from each other (from shallowest to deepest), and in general isolation will be maintain between these groups: Eyre Winton Mackunda Corrikiana Cadna-owie Murta (including McKinlay Member) Namur, Adori Birkhead, Hutton, Poolowanna Cuddapan; Nappamerri Group formations,

Walkandi and Peera Peera formations Toolachee; Daralingie Epsilon, Patchwarra or Mt Toodna or Purni Tirrawarra sandstone or Stuart Range;

Merrimelia; Boorthanna; Crown Point formations and Basement reservoirs

Note: Crossflow (if it occurs), should not compromise the long term sustainability of a particular resource.

Casing annulus pressures are monitored every 2 years.

The condition of the primary casing barrier is adequate.

For cases where crossflow is detected, a risk assessment incorporating the use of pressure / permeability / salinty data is undertaken in consultation with DLWBC & AAWCMB to determine if lack of cement or poor bond will cause or has caused damaging crossflow which needs to be remediated.

Well Abandonment Activities Isolation barriers are set in place to ensure that

crossflow, contamination or pressure reduction will not occur.

Barriers will be set to meet or exceed the requirements of applicable standards for the decommissioning and abandonment of water bores and abandonment of petroleum wells.

The placement of isolation barriers will in general be to isolate the groups of formations as listed under comments. The number and placement of barriers may be varied from this standard approach on a case-by-case basis by SACB Operator personnel using relevant available data and the SA Cooper Basin Water Pressure and Salinity Module Report (2002), and in consultation with DWLBC.

Objective 7: Minimise disturbance to native vegetation and native fauna.

Primary risks to native fauna include clearing of habitat and obstruction of movement through cleared areas, the presence of borrow pits, fuel and chemical storage and management, and waste management activities.

Well Lease and Access Track Construction and Restoration Proposed well sites, camp sties, access tracks

and borrow pit sites have been assessed for rare, vulnerable and endangered flora and fauna species before the commencement of

Well Lease and Access Track Construction and Restoration Any site with rare, vulnerable

and endangered flora and fauna have been identified and avoided.







Statement

construction. Consider alternate routes during planning phase to

minimise environmental impacts. Facilities (eg. borrow pits, well cellars) are

designed and constructed as far as practicable to minimise fauna entrapment.

Sumps and mud pits are fenced as appropriate to minimise wildlife access

Assessment records are kept and are available for auditing.

In recognised conservation reserves (ie. Innamincka Regional Reserve) excavations are left in a state as agreed with the responsible statutory body

Borrow pits are restored to minimise water holding capacity, where agreements are not in place with stakeholders.

Waste Management Covered bins are provided for the collection and

storage of wastes. All loads of rubbish are covered during transport to

the central waste facility Pits are not established locations, which pose an

unacceptable hazard to stock or wildlife.

0, +1 or +2 GAS criteria are attained for "Minimise impacts on vegetation" objective as listed in Appendix 2, during well lease and access track site selection and construction and for "Re-establish natural vegetation on abandoned well sites and access track" objective in Appendix 4.

Borrow Pits Construction and Restoration 0, +1 or +2 GAS criteria are

attained for "Minimise impacts on vegetation" objective as listed in Appendix 4 during borrow pit site selection and construction, and "Minimise Impact on Vegetation" objective in Appendix 5 for borrow pit restoration.

Waste Management Refer to assessment criteria for

Objective 11

Fuel and Chemical Storage and Management Refer to assessment criteria for

Objectives 2 and 4

Compliance Statement: GDY to its knowledge and through implementing the EIR requirements believes that it has complied with all obligations required under this SEO objective.







Statement

Objective 8: Minimise air pollution and greenhouse gas emissions.

Atmospheric emissions occur as a result of standard practices undertaken during drilling and well operations. Emissions of particular environmental significance are: Combustion by-products (eg. oxides of

nitrogen, carbon monoxide and sulphur dioxide);

Organic carbon and carbon particulates (black smoke); and

Flared/vented hydrocarbons (gases)

Well Testing Conduct well testing in accordance with

appropriate industry accepted standards Continually review and improve operations Appropriate emergency response procedures are

in place for the case of a gas leak

Well Blowdown Blowdown carried out in accordance with industry

accepted standards / good production practice Any well that is consistently blown down is

indentified for a small ID tubing or plunger lift installation to minimise blow downs on that well.

Compliance with EPA requirements.

Compliance Statement: GDY to its knowledge and through implementing the EIR requirements believes that is has completed with all obligations under this SEO objective.

Objective 9: Maintain and enhance partnerships with the Cooper Basin Community.

The importance of liaison with and contribution to the local community is recognised by the South Australian Cooper Basin Operators. Notification, consultation, contribution to community activities, projects and events and membership of relevant organisations are considered to be key strategies for ensuring partnerships with the local community are enhanced.

Relevant affected parties are notified and consulted on proposed activities.

Forward development plans are presented to the local community.

Local community projects and events are sponsored and supported where appropriate.

Industry membership of appropriate regional land management committees and boards ie. the Lake Eyre Basin Consultative Council, Marree Soil Conservation Board and Catchment Committees.

No unresolved reasonable complaints from the community.

Compliance Statement: GDY to its knowledge and through implementing the EIR requirements believes that it has complied with all obligations under this SEO objective.

Objective 10: Avoid or minimise disturbance to stakeholders and/or associated infrastructure.

Communication and the establishment of good relations with stakeholders and community is fundamental to minimising disturbance to as low as practicably possible. Many pastoral properties are certified under the Organic Beef or CattleCare accreditation schemes and therefore may be affected by fuel and chemical storage, moving machinery and contaminated sites.

Induction for all employees and contractors covers pastoral, conservation, legislation and infrastructure issues.

Relevant stakeholders are notified prior to survey and construction of well sites, camp sites and access tracks and undertaking of operations (pursuant to Petroleum Regulations). Borrow pits left open (unrestored) if requested by landholder and upon receipt of letter of transfer of responsibility to landholder.

No reasonable stakeholder complaints left unresolved.

Compliance Statement: GDY to its knowledge and through implementing the EIR requirements believes that it has completed with all obligations under this SEO objective.







Statement

Gates or cattle grids are installed to a standard, consistent with pastoral infrastructure in fences where crossings are required for access.

All gates left in the condition in which they were found (ie. open/closed).

Potential sources of contamination are fenced as appropriate to prevent stock access.

System is in place for logging landholder complaints to ensure that issues are addressed as appropriate.

Requirements of the Cattle Care and Organic Beef accreditation programs are complied with.

In recognised conservation reserves (ie. Innamincka Regional Reserve) excavations are left in a state as agreed with the responsible statutory body.

Objective 11: Optimise waste reduction and recovery.

Waste reduction requires continual improvements in purchasing, efficiency of use and reuse. Due to the distances involved, the costs of recycling a large range of products is not possible however continual review of recycling options is required to ensure that any opportunities are taken advantage of.

Bulk chemical and oil purchasing and use of "bulki bins" or other storage tanks in place for large volume items.

With the exception of drilling fluids, drill cuttings and other fluids disposed during well clean-up, and sewage wastes, all wastes to be disposed of at an EPA licensed facility in accordance with EPA licence conditions.

Attainment of GAS criteria for "Site left in clean, tidy and safe condition after final clean-up" objective during well site restoration (refer Appendix 4).

Attainment of GAS criteria for "Site left in clean, tidy and safe condition" objective during borrow pit restoration (refer Appendix 5).







Statement

Compliance Statement: GDY to its knowledge and through implementing the EIR requirements believes that it has complied with all obligations required under this SEO objective.

Objective 12: Remediate and rehabilitate operational areas to agreed standards.

Rehabilitation / abandonment plans for surface activities will be developed in consultation with relevant stakeholders. Well Site and Access Track Restoration Compacted soil areas have been ripped (except

on gibber and tablelands) and soil profile and contours are reinstated following completion of operations.

No unresolved reasonable stakeholder complaints.

Contaminated Site Remediation Contaminated sites are

remediated in accordance with criteria developed with the principles of the National Environment Project Measure for Contaminated sites and in consultation with the EPA.

Well Site and Access Track Restoration The attainment of 0, +1 or +2

GAS criteria for (refer Appendix 4): "Minimise visual impact of

abandoned well sites" "Minimise visual impact of

abandoned access tracks" "re-establish natural vegetation

on abandoned well sites and access tracks"

Borrow Pit Restoration The attainment of 0, +1 or +2

GAS criteria for (refer Appendix 5): "Minimise impact on







Statement

vegetation" "Minimise impact on soil" "Minimise visual impacts"

Compliance Statement: As remediation and rehabilitation is yet to take place is not appropriate to provide a compliance statement on this issue at this time.



Appendix D Geodynamics' compliance for construction and operation of the

1MW pilot plant



Geodynamics compliance for construction and operation of the 1MW Pilot Plant

SEO: 1MW Geothermal Power Plant at Innamincka

Environmental Objectives Assessment Criteria Assessment Criteria Assessment and Compliance

Statement

15. Minimise impact to soil

No soil contamination due to site activities

No erosion due to construction and operation as far as practicable

Stockpiles established of topsoil and gibber material in areas to be impacted by site activities unavoidable

Storage of fuels and chemicals in accordance with EPA Guideline 080/07 Bunding & Spill Management, AS & Best Practice Management

Regular inspection of storage areas to ensure integrity good housekeeping and correct use

Clean-up of any spills Waste collected and stored on site for short

period in a single storage area then disposed of offsite

No burial or burning of waste onsite Design of wastewater treatment plant in

accordance with Dept Health requirements Maintenance of wastewater treatment plant in

accordance with manufacturers manual Infiltration of wastewater in accordance with

sustainable practices Restrict earthworks to as small an area as

practicable and within existing footprint

Impacts to soil have been minimised and earthworks restricted to as small an area as possible. There was some minor contamination of soil due to effluent from the camp. The WWTP has been rectified and is now operating in accordance with the Department of Health conditions of approval. Compliance Statement: In all other respects GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

16. Minimise disturbance to native vegetation

Clearance of native vegetation is avoided as far as practicable

Any areas of threatened species have been identified and infrastructure located well away

Native vegetation not impacted by dust

Induction of site personnel on requirement relating to native vegetation

Minimise vegetation clearance and plan construction to avoid vegetation areas and clearance if required prior to construction. No go areas to be flagged.

Restriction of traffic movement and management of soil stockpiles to ensure minimal dust generation and smothering of vegetation

Site was cleared by survey undertaken by environmental consultant

Imported fill (if required) to be checked and free of weeds

Reporting of unauthorised native vegetation clearance

Site personnel inducted and records kept

Vegetation clearance has been minimised and traffic movement restricted to designated tracks. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.






Statement

17. Minimise potential for weed introduction and undertake control measures where necessary

Weeds not introduced or spread at the site

Induction of site personnel on restrictions

Minimise time exposure of cleared land Undertake vehicle wash down before entering

Cooper Basin area or after operating in high risk areas or areas of known weed infestation

Vehicles and equipment restricted to tracks and formed roads in project area. Where possible work in less disturbed areas and move to more disturbed areas to avoid weed transfer

Removal of weeds and keep of records of weed eradication

Site monitored to see if new weed species introduced

Potential for weed introduction has been minimised. Vehicles and equipment restricted to tracks and formed roads in the project area. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

18. Minimise disturbance to fauna

Clearance of native vegetation is avoided as far as practicable

Pest fauna species not introduced or spread at the site

Induction of site personnel on requirements relating to fauna including speed restrictions

Noise levels maintained to EPA noise policy requirements

Site was cleared by survey undertaken by environmental consultant

Limited clearance of vegetation to specified areas and immediately prior to construction

Management Plan for construction activities Any areas of threatened species have been

identified and infrastructure located well away Minimise impacts by not leaving trenches open

for long periods Monitor open excavations daily for fauna

entrapment and provide fauna escape routes where feasible

Induction to include how to dispose of butts/litter that may be ingested by fauna

Reinstate construction area ASAP Appropriate waste management measures Fencing of the operations area Record of pest species kept Minimise night time work to minimise noise and

light and keep night time lighting to minimum

Clearance of native vegetation has been avoide. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.






Statement

required to ensure safety

19. Minimise impact to groundwater

No aquifer contamination as a result of site activities including fuel and chemical storage waste storage and operation of wastewater treatment plan

Extraction of groundwater in accordance with DWLBC licence

Monitoring of water levels in McLeod's and Darby's Bores

Waste to be stored in lidded bins or storage containers and segregated for recycling

There has been no contamination of aquifers as a result of site activities. Water levels in Darby's bore have been monitored. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

20. Minimise impact to surface water

No disruption to drainage pattern as a result of site activities

No contamination of soil due to spill of fuels or discharge from wastewater treatment plant

Inspections after heavy rainfall Install sediment control features Waste storage area to be located well away

from potential drainage areas or floodplain Minimise generation of waste Reduce, reuse, recycle

Impacts on surface water have been minimised. Sediment control features have been installed. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

21. Minimise impact on air quality

No significant discharge of dust offsite

Combustion emissions in accordance with regulatory requirements

Minimise area of disturbance Traffic speed reductions Controlled use of water and other dust

suppressants Emissions to be in accordance with Air Quality

Policy Vehicles and machinery fitted with appropriate

emission control equipment and maintained in accordance with manufacturers requirements.

Impacts on air quality have been minimised.


22. Minimise impacts to the amenity of stakeholders by dust, noise, odours

No complaints from public

Compliance with EPA noise policy Monitor complaints Regular servicing of equipment and noise

control measures No burning of waste

Impacts on the amenity of stakeholders have been minimised as far as possible.

Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO






Statement

Waste transported in covered vehicles objective.

23. Minimise visual impact No complaints received from public

Design and construction with materials that minimise visual effect

No complaints have been received from the public. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.

24. Minimise impacts to sites of indigenous and non-indigenous heritage

No impacts to sites of indigenous and non-indigenous heritage

Existing sites have been identified as part of previous work clearances

Clearance from native title holders of new components of project before construction activities commence.

Compliance with Aboriginal Heritage Act 1988 if objects uncovered

Compliance with Heritage Places Act 1993 Relocation of infrastructure if required.

Heritage clearance undertaken prior to commencement of activities. There have been no impacts to heritage sites.


25. Minimise risks to the safety of the public and workforce

No injuries to public as a result of construction and operations

No health impacts as a result of exposure to radioactive substances and radon emissions

No explosion or fire at site

Site fenced & no site access to general public "No Entry" signs posted, together with

appropriate Dangerous Goods signage Plants operated in a 'closed loop' Management of operations of the plant in

accordance with operating procedures and emergency response plans

No explosion or fire at site Groundwater and sediment from water tested to

ensure no risks to human health Operation in accordance with H&S plan Contingency / emergency procedures in place Transport of chemicals and fuel in accordance

with the ADG codes

Risks to safety of public and workforce have been minimised. Since the incident at Habanero 3 and exclusion zone has been set up around Habanero 1. The site is fully fenced and no entry signs erected.







Statement

Regular education and training of drivers Speed restriction on unsealed roads Vehicles maintained and serviced regularly No transportation during wet conditions Restriction of transportation at night Establishment of appropriate spill management,

register & cleanup procedures Immediate cleanup of spills

26. Minimise impacts to existing land uses

No adverse impact on ongoing use of land for pastoral activity if full scale operations do not proceed

No significant impact to Innamincka Regional Reserve

No reasonable concerns raised by stakeholders left unresolved

No adverse impact on livestock

No impact on local roads due to spills

Immediate cleanup of spills Periodic review and practice of emergency

response procedures Maintain a complaints register Limit footprint of operations Site fenced Notification to pastoral owner in event of

collision with cattle and appropriate compensation

Notification to owner of construction timing

Impact to existing landuses have been minimised. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required until this SEO objective.

27. Rehabilitation and closure to be undertaken to agreed standards

Site rehabilitation to acceptable standard

Soil restoration in accordance with Appendix B

Vegetation restoration in accordance with criteria in Appendix B

Removal of infrastructure and rubbish in accordance with Section 8 of EIR

Scarify areas of compacted soil, except gibber areas after decommissioning

Return land to pre-existing use and conservation value of the surrounding area, to satisfaction of the lease holder and land owner

Assess the potential for contamination Ensure stockpiled soil is kept to appropriate

heights

Rehabilitation and closure will be undertaken to agreed standards. Compliance Statement: GDY to its knowledge believe it has complied with all obligations required under this SEO objective.






Statement

Ensure topsoil in respread evenly

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