May 29, 2009 [Date of Submission]
Department of Infrastructure and Planning
PO Box 15009
CITY EAST, QLD 4002
Dear Sir/Madam,
Comments on CSG Water Discussion Paper
Below I provide some comments in response to Queensland Government’s call for public commenting on a number of specific issues related to its new policy on the management of CSG water as outlined in the discussion paper entitled: “Management of Water Produced from Coal Seam Gas Production”, dated May 2009 (“Discussion Paper”). For clarity of my points I recommend that my comments to be read in conjunction with the attached set of slides entitled “Management of Coal Seam Gas Water” (Shown below and referred to as “GEO slides”).
For preparing these comments I have drawn from my experience in dealing with produced water and various aspects of saline water characterization and treatment for beneficial use. I have attached my brief resume for your information. I have also discussed the points raised in the Discussion Paper with my Australian and U.S. colleagues and in this relation I am particularly indebted to Dr. Mike Mickley, an international expert on aspects of desalination waste management, for his constructive suggestions and in-depth knowledge of the issues and the opportunities for beneficial use of produced water.
A. General Comments
Firstly, I would like to commend the Queensland Government for its new policy position with respect to coal seam gas water (CSG water) management. The discontinuation of evaporation ponds as a primary means for disposal of CSG water and the new policy framework that encourages maximum beneficial use of water are two key features of this policy. These will hopefully strengthen the regulatory framework for CSG development in Australia, including water management and disposal. Also confirming that the CSG producers are responsible for treatment and disposal of CSG water is another feature of the policy, although considering the existing regulatory guidelines in Queensland I assume this was expected to be a prevailing case. Considering the volume of water expected to be generated through the course of developing an LNG industry in the State, I am pleased that your Government is providing a clear and timely policy direction for the management of CSG water while also clarifying the role it will play in facilitating the development of the industry in an environmentally sound manner.
Secondly, I provide the following general comments with reference to the overall topic of the Discussion Paper:
Comment 1:
Given the projected imbalance between the volume of CSG water production over the next 30 years and the demand for this water by potential users, the Government should encourage maximum use of water for land application in preference to other options which appear to have limited scope and applicability in the case of Queensland. The Government may facilitate this process through instigating a scoping study that screens the existing and new information to establish the range of technical and notional commercial applicability of land application of CSG waters for a range of water quality parameters and flow rates. Such a “land applicability envelope” will be a very useful tool to assist the CSG producers in developing their water management plans and ranking their water resources for detailed evaluations.
Comment 2:
In view of the number and size of the proposed LNG projects, a sustainable management of CSG water will require consideration of both water quality and volume (flow) issues. As the water quality issues (salinity, alkalinity and sodicity/SAR) are often inter-related, the solutions for maximum land application of CSG water will require evaluation of site-specific conditions and project-specific requirements with reference to changing flow rates, TDS salinity and water degradation through time. As flow rates and TDS salinity are site specific the solutions for managing water may vary significantly between now and the peak of LNG production and between different CSG producers.
Comment 3:
CSG water is an alkaline water (largely because of the elevated concentration of HCO3 ion) and thus susceptible to loss of CO2 upon impoundment. The following formula reflects the situation with Na-HCO3 and Na-HCO3-Cl water types.
2NaHCO3 < ---- > Na2CO3 + H2O + CO2 ^
Accordingly, I suggest that all CSG producers should be encouraged to develop and implement water management plans that are geared towards maximum water recovery from desalination processes while producing reject brines with minimum or no HCO3 content. This approach will enable the CSG producers to reduce the physical and carbon footprint of their operations and reduce the costs associated with downstream treatment of desalination brine before storage/disposal. This may also require the introduction of a HCO3 trigger if the proposed aggregation and disposal became the brine management system of choice. Modelling life-cycle cost will enable companies to differentiate the cost components of various water treatment options in preparation for carbon accounting under the forthcoming national carbon trading regime.
Comment 4:
Considering the quality of CSG water from Surat and Bowen Basins I agree with the Government that the beneficial uses for CSG water will be limited unless it is treated. However, it will be a combination of pre-treatment, desalination, SAR and alkalinity reduction steps together with blending that will ultimately define the extent of land applicability of CSG water, particularly for cropping (potentially the largest end use area). Based on available water quality and flow information one of the biggest challenges will be the choice of technologies (or a combination thereof) for achieving the best economy of scale for producing treated waters with low salinity, alkalinity and SAR for use in large-scale watering of high value crops. Because the TDS, SAR and soil type are inter-related, for large-scale land application of CSG water an effective method for the reduction of alkalinity (HCO3) of CSG waters will be needed in order to avoid the incipient precipitation of carbonate minerals and whitening effects at soil/water interface. Appropriate technologies are available to address these water quality issues and the earlier suggested scoping study for developing a “land applicability envelope” my view include an in-depth review of the technical and economic aspects of these technologies.
Comment 5:
Considering the scale of proposed LNG projects and water recovery rates of conventional desalination processes, there will be a large volume of waste brine generated by the individual CSG producers, which will need safe disposal. The disposal of inland desalter brines is a global issue and not unique to Queensland. Consequently, it will be to the advantage of CSG companies to collaborate with the Government and invest in developing and implementing a well defined state-wide “waste minimization strategy” based on recent technological developments and the principles of multi-stakeholder Best Management Practices (BMPs). Along this line of thought I also suggest that the EMPs required from CSG companies under the EP Act should allow consideration of both options for regulated discharge (i.e. via aggregation and storage) and zero liquid discharge (ZLD).
B. Specific Comments in Relation to Issues Raised in the Discussion Paper
Comment 6 in Relation to Issue 1:
From our company’s previous experience I believe that it will be to the advantage of CSG industry to cooperate with the State Government to develop and fund one or more CSG water aggregation and disposal systems when direct injection or beneficial use is clearly no longer an option for further consideration. Although several water management issues could benefit from such collective action and cost sharing I have concerns that a tight time frame for reaching a collective agreement on water transport and aggregation may become a restrictive factor for those CSG producers who wish to fast track the development of their LNG projects. Furthermore, being a new proposition, while the energy companies may be agreeable to absorbing the capital costs associated with developing such system(s) there could be a degree of concern with incurring the operation costs particularly if the risks and liabilities associated with contamination due to aggregation and disposal become high. For improving the industry’s confidence in such a collective action the Queensland Government may need to demonstrate the long-term advantages of aggregation and disposal and also its preparedness in adjusting the regulatory policy and procedure, to the extent of adopting an overreaching new umbrella status for the management and regulation of CBM development (i.e., a “CSG Management Act”).
In summary, a clear model for the option of “total solution” for the unwanted or excess CSG water may need to be developed by the Government and presented to the industry before finalizing the circumstance under which industry should be required to cooperate to develop and fund a CSG water aggregation and disposal system(s). An industry-led formulation of BMPs for CSG water could also help in fine tuning the definition of ‘circumstances” to the mutual benefit of industry, Community and environment alike.
Comment 7 in Relation to Issue 2:
I have assumed that during the three-year time frame for completing the remedial action the CSG companies will be able to discharge CSG water from their current operations in the existing evaporation ponds until the transition plan in accordance with the new policy is finalized. In this case, converting the evaporation ponds to landfill sites would probably be the only practical option, unless the Government takes the initiative and establishes beforehand a dedicated landfill facility at its own or shared cost.
Comment 8 in Relation to Issue 3:
As indicated in the accompanying GEO Slides, the options for sustainable disposal of saline effluents resulting from the treatment of CSG water are limited and can be expensive. One approach is the use of custom designed evaporation ponds which through time may be converted to landfills by using encapsulation and capping methods. As there would be no further beneficial use of water, such a site would need to be developed and managed in long-term as a contaminated site.
Another option would be the beneficial use of RO brine for recovery of one or more useful byproducts, as schematically shown in GEO Slides. The economics of integrated recovery of water and byproducts from such brines will depend on water quality parameters, the flow rate that is available for treatment and market demand for byproducts. The recovery of salt is technically possible by a variety of conventional and thermal methods and in some cases through hybrid arrangement of solar ponds and thermal crystallisers.
The costs associated with the safe disposal of brine from inland desalination facilities are known to be often high and therefore all options for waste minimization and value adding may be considered as a means to offset the treatment cost. Although I agree that brine storage ponds should be lined and operated in accordance with EPA guidelines, I also suggest that all existing and emerging technological options to be systematically evaluated by the Government and the CSG industry with the objective of minimizing waste generation and thus reducing the number of contaminated sites.
While the importance of LNG industry to the economic well being of the State is well recognised, important fundamental changes in CSG water management and regulation are already underway. I think that there is now an opportunity to avoid heavy reliance on engineering solutions and encourage the CSG industry to embrace technology-based solutions for broadening the scope of beneficial use of CSG water while creating opportunities for landowners to allocate land for additional uses of water. These opportunities will be available only if water quality is suitable and the adverse environmental consequences of land application are minimised.
Comment 9 in Relation to Issue 3:
A possible option (least desired) for the disposal of large volumes of saline CSG water that has no immediate or medium-term beneficial use would be the establishment of a series of infiltration ponds within the confines of a hydrologically closed basin, preferably with one or more saline aquifers. These infiltration ponds can be designed to function similar to those leaky ponds of the Salt Interception Schemes long operating along the course of Murray River in the southern States. In this case, the disposal water quality guidelines would probably need a HCO3 trigger to avoid excessive precipitation of carbonate minerals and clogging of the infiltration pathways.
Yours sincerely,
Aharon Arakel, PhD
President & Chief Technologist
Geo-Processors Pty Limited
Geo-Processors USA, Inc.
www.geo-processors.com
Aharon Arakel – Brief Resume
Dr. Aharon Arakel obtained his PhD in earth sciences from The University of Western Australia. He is an expert on land and water salinisation issues and at the forefront of development and application of innovative saline water treatment technologies for salinity management and saline wastewater minimization. Dr. Arakel is the lead inventor of several patented technologies for saline water treatment systems. He has over 30 years experience in providing expert advice to water, energy, oil/gas, mining and food processing industries in Australiasia, U.S.A., Middle East and South Africa on various aspects of sustainable salinity control and saline waste management. His recent research and technology development efforts have related to process chemistry of brine treatment systems, selective salt recovery processes and carbon capture and storage using chemical sorbents prepared from industry effluents. The U.S. examples of his research efforts include several contributions to collaborative and contract research projects on desalination concentrate management. He is currently engaged on a project involving the development of an information clearinghouse on concentrate and salt management practices, a research project funded by the U.S. WateReuse Foundation.
Dr. Arakel has produced a wide range of research, technical and popular publications and is a member of a number of professional societies in Australia and U.S.A. He has previously acted as a director of SALINET, a US-based international salt lake research consortium, and until recently was a member of the Management Committee of Specialist Group on Membrane Technology of the International Water Association (IWA).
