EXPERT REPORT CONCERNING GEOLOGIC AND HYDROGEOLOGIC ASPECTS OF TETRA4’S CLUSTER 2 VIRGINIA GAS PRODUCTION PROJECT, VIRGINIA, FREE STATE PROVINCE, SOUTH AFRICA

This expert report, prepared by geologist and hydrogeologist Steven K. Campbell for the Centre for Environmental Rights, critiques the Environmental Impact Assessment (EIA) for Tetra4 (Pty) Ltd’s proposed Cluster 2 gas production expansion near Virginia, Free State Province, South Africa. Campbell argues that the project's geologic and hydrogeologic frameworks are based on insufficient site-specific data, leading to unreliable groundwater flow models and flawed contamination simulations for methane and total dissolved solids (TDS). He concludes that the expansion should not be approved until critical data gaps are filled and a robust monitoring and remediation plan is established.

• The EIA contains significant geologic discrepancies and lacks site-specific structural geology, borehole logging, or geophysical data from Cluster 1 wells, making it impossible to accurately project natural gas and groundwater migration pathways. The proposed expansion would introduce approximately 90,000 meters of open borehole, which Campbell opines will "dramatically increase groundwater migration pathways".
• Tetra4 has failed to produce a validS meaningful Conceptual Site Model (CSM) as defined by industry standards (e.g., ASTM Practice E1689-20). The report states that Tetra4's provided imagesS images are merely "block diagrams that are routinely used in textbooks" and doS do not incorporate new data from Cluster 1 gas-production wells.
• The groundwater equipotential map used by Tetra4 is considered unreliable because it relies on water-supply wells (WSWs) of unknown construction, many of which are actively pumping, and uses a non-standard representation of depth-to-groundwater via "opaque yellow spheres" that obscure map details.
• The computer model of the Karoo aquifer is described as fundamentally flawed because it treats the system as a simple-porosity (intergranular) system, ignoring the real-world predominance of flow through fractures, faults, and mine voids.S. Additionally, approximately 85% of the model domain lacks field-measured head data to constrain flowS flow patterns.
• ContSS contamination simulations for TDS and methane are deemed unreliable. TDS simulations project that by year 120, polluted areas in the Karoo and surficial aquifers will increase to ~1,456 hectare and ~7S 770 hectare, respectively. Methane simulationsSS simulations project impacts increasing to ~644 hectare in the Karoo and ~393 hectare in the surficial aquifer over the same period.
• The proposed groundwater monitoring plan is criticized for relying on repurposed water-supply wells rather than intentionally designed monitoring wells. Campbell argues that the use of "micropurge" sampling is inappropriate as it samples stagnant wellbore storage and may miss contaminated water from multiple fractures.
• The report identifies critical omissions in the monitoring plan, specifically the lack of testing for hexavalent chromium (Cr+6), thorium, and other radiologicals, despite the fact that helium is produced by radioactive alpha decay. Furthermore, the author notes a total absence of a specific remediation plan for detected groundwater contamination.

APA

Campbell, S. K. (2023). EXPERT REPORT CONCERNING GEOLOGIC AND HYDROGEOLOGIC ASPECTS OF TETRA4’S CLUSTER 2 VIRGINIA GAS PRODUCTION PROJECT, VIRGINIA, FREE STATE PROVINCE, SOUTH AFRICA. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2025/06/Annexure-A1.pdf?x21779

Chicago

Campbell, Steven K. EXPERT REPORT CONCERNING GEOLOGIC AND HYDROGEOLOGIC ASPECTS OF TETRA4’S CLUSTER 2 VIRGINIA GAS PRODUCTION PROJECT, VIRGINIA, FREE STATE PROVINCE, SOUTH AFRICA. Centre for Environmental Rights, 2023. https://cer.org.za/wp-content/uploads/2025/06/Annexure-A1.pdf?x21779.

Wikipedia

{{cite report |last1=Campbell |first1=Steven K. |title=EXPERT REPORT CONCERNING GEOLOGIC AND HYDROGEOLOGIC ASPECTS OF TETRA4’S CLUSTER 2 VIRGINIA GAS PRODUCTION PROJECT, VIRGINIA, FREE STATE PROVINCE, SOUTH AFRICA |publisher=Centre for Environmental Rights |date=20 July 2023 |url=https://cer.org.za/wp-content/uploads/2025/06/Annexure-A1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{campbell2023expert, author = {Campbell, Steven K.}, title = {{EXPERT REPORT CONCERNING GEOLOGIC AND HYDROGEOLOGIC ASPECTS OF TETRA4’S CLUSTER 2 VIRGINIA GAS PRODUCTION PROJECT, VIRGINIA, FREE STATE PROVINCE, SOUTH AFRICA}}, institution = {Centre for Environmental Rights}, year = {2023}, month = jul, url = {https://cer.org.za/wp-content/uploads/2025/06/Annexure-A1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }