Write a submission to stop Imperial Oil and Gas

Your chance to say NO to NT gas drilling plans

Imperial Oil and Gas are right now seeking permission to drill for shale gas in the wet season just 85 kms south-west of Borroloola within the Carpentaria and McArthur Basins. This drilling program will threaten communities, land, air and water. 

Submissions close on 31 July. 

It’s really important to have your say on this project and lodge your objection.

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Thank you for taking action to protect the Northern Territory from fracking gas fields. 


To: [email protected]

Subject: Objection to Imperial Oil and Gas wet season drilling program EP 187


Dear Department of Environment and Natural Resources,

I am writing to express my objection to the Revised Environmental Management Plan submitted 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 are a number of possible negative impacts to people and communities posed by Imperial’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 or the Tenement. The nearest property is OT Downs Homestead located approximately 20km North-West of the proposed area.



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

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

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



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

It is deeply concerning that instead of storing toxic wastewater in enclosed tanks, Imperial Oil and Gas is planning to use open pits and unattended open-top tanks in the wet season. Not only could this kill birds, but extreme weather events could cause downstream pollution impacts. 

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



Cuttings and solid drilling residue initially stored in a lined pit. Subject to sampling and testing results drill cuttings will be buried and disposed in-situ (on site). This disposal 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 waste will be disposed of to a licensed facility in Queensland. Residual drilling mud in the drill cuttings sump that does not evaporate and fails to meet disposal requirements as outlined in the Code will be removed from site, before the onset of monsoon rains for disposal at a licensed facility in Queensland. This is not good enough, if this waste is too dangerous for the NT why should Queenslanders be forced to live with their toxic waste disposal?



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

The Environment Protection & Biodiversity Conservation Protected Matters Search Tool identified 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 a moderate likelihood of occurrence.



It is anticipated that 2.5ML of water will be required for Imperial Oil and Gas’ drilling activities. 

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 integrity failure. 
  • Impact to hydrological systems due to chemical spills, lack of appropriate bunding and poor 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

The McArthur River is the primary surface water, water drain of the exploration area. This water course drains the whole area into the Gulf of Carpentaria. The Glyde is the main tributary to the McArthur River and lies to the east of the study area. 

The Chambers River Formation and Cambrian Limestone provide regional scale aquifers for groundwater resources available for pastoral enterprises, domestic bores at homesteads and town water supplies several remote communities across the region.

Among the various formations to be intersected during drilling, the Gum Ridge Aquifer is expected to be encountered at an approximate depth of 100-150m. 

Imperial Oil and Gas state that they will use “a cemented production casing string to provide additional protection barrier between producing hydrocarbon bearing zones and shallow aquifers”. However it is well known that cement will crack overtime and this would be disastrous. 

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



Imperial Oil and Gas admits that it’s wells are designed to be drilled utilising water-based muds 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 Weighting agent/viscosifier Calcium Carbonate Weighting agent/Bridging agent Caustic Soda pH adjustment Citric Acid pH adjustment Glut 9 Biocide Magnesium Oxide Conditioning chemical PAC LV Fluid loss additive PHPA Encapsulation Potassium Carbonate Potassium carbonate Potassium Chloride (KCl) Inhibitor Salt Weighting agent SAPP (Sodium Acid Pyrophosphate) Dispersant Soda Ash pH adjustment Sodium Bicarbonate pH adjustment Sodium Sulphite Oxygen scavenger TEA HT polymer stabiliser Thinpool Thinner Xanthan Gum Viscosity. These chemicals could have an impact on the quality of soil and water in the area 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 pose a contamination threat to soil, surface water and groundwater. 



Imperial Oil and Gas admits that “In the event of produced gas, flaring rather than venting will be implemented for emergency purposes.” This is a risk to the air quality of nearby communities.

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



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



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



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

Thank you for considering my concerns,

Your name, address and contact details

July 17, 2020 at 6:00pm - 9pm
Daniel Robins

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Daniel Robins

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