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Code of Practice for coal seam gas well head emissions detection ...

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. For leaks identified on <strong>well</strong> equipment - higher order controls, such as containment by<br />

repair, must be implemented wherever possible.<br />

c. For leaks identified on <strong>well</strong> casings or adjacent to the <strong>well</strong> casing (where a work over rig<br />

is necessary to affect repair) - determine whether the leak requires immediate repair, or<br />

whether the risk can be adequately managed via other control measures until a work over<br />

<strong>of</strong> the <strong>well</strong> is scheduled <strong>for</strong> normal operational reasons. The risk assessment to<br />

determine the above must consider the location <strong>of</strong> the <strong>well</strong>, likely access to the <strong>well</strong> from<br />

landholders or the general public, and landholder/community concerns in relation to the<br />

leak.<br />

7. Provide a written close-out report to the P&G Inspectorate within 96 hours <strong>of</strong> <strong>detection</strong> <strong>of</strong> the<br />

leak, specifying the date <strong>of</strong> identification, nature and level <strong>of</strong> leak, location and name <strong>of</strong> the<br />

<strong>well</strong>, the rectification actions taken or proposed and the current status <strong>of</strong> the leak (e.g.<br />

isolated, repaired, etc).<br />

8. If remediation is delayed <strong>for</strong> any reason then a final close out report must be provided when all<br />

work is completed.<br />

The P&G Inspectorate may upon review <strong>of</strong> the report and risk assessment require further<br />

in<strong>for</strong>mation or action in accordance with its en<strong>for</strong>cement policy and regulatory role.<br />

Extensions<br />

If a risk assessment determines that the risks <strong>of</strong> immediately repairing a leak exceed the risk<br />

posed by the leak, this can be considered as grounds <strong>for</strong> extension <strong>of</strong> the 48 hour remediation<br />

period, provided that other measures to mitigate the risk are undertaken (e.g. ensuring no ignition<br />

sources or personnel are permitted in the exclusion zone). The P&G Inspectorate must be notified<br />

(be<strong>for</strong>e the expiry <strong>of</strong> the 48 hour remediation period) <strong>of</strong> the proposed delay.<br />

Internally reportable leaks<br />

In the event that a CSG operator detects an “Internally Reportable Well Head Leak” (see<br />

definitions) at any CSG <strong>well</strong> site facility, the CSG operator must promptly respond in accordance<br />

with the actions specified in the relevant CSG operator’s ‘Leak Management Plan’ and other safety<br />

management plan requirements.<br />

On an annual basis (via the annual safety report), a summary <strong>of</strong> all <strong>well</strong> <strong>head</strong> reportable leaks and<br />

internally reportable leaks must be provided to the P&G Inspectorate.<br />

Protection <strong>of</strong> CSG <strong>well</strong> site facilities<br />

Appropriate signage, barriers and/or security fencing to isolate CSG <strong>well</strong> site facilities must be in<br />

place <strong>for</strong> all <strong>well</strong> site facilities as determined by the CSG operators risk assessment and<br />

management. The risk assessment must be consistent with AS/NZS:60079 Explosive<br />

atmospheres Part 10.1:2009 and will consider:<br />

1. Risks posed by third parties and the general public based on proximity <strong>of</strong> the CSG <strong>well</strong> site<br />

facilities the ownership <strong>of</strong> land, and the accessibility <strong>of</strong> the CSG <strong>well</strong> site facilities to the<br />

general public; and<br />

2. The magnitude <strong>of</strong> the risk posed by the CSG <strong>well</strong> site facilities, which may be dependent on<br />

the type <strong>of</strong> <strong>well</strong> completion the equipment/facilities installed at these sites and the pressure,<br />

flow rate and composition <strong>of</strong> the <strong>gas</strong> contained by the facilities.<br />

CSG operators must ensure that all required fencing and signage is in place after the <strong>well</strong> is drilled<br />

and also after surface equipment is installed.<br />

<strong>Code</strong> <strong>of</strong> <strong>Practice</strong> <strong>for</strong> CSG <strong>well</strong> <strong>head</strong> <strong>emissions</strong>, <strong>detection</strong> and reporting - Version 2 June 2011 10

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