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

The report critiques Tetra4's Cluster 2 gas expansion, citing significant data gaps in structural geology and hydrogeology. The author argues that the company's groundwater flow models and contamination simulations for methane and total dissolved solids (TDS) are unreliable because they ignore the complex nature of fractured-rock aquifers. Furthermore, the report contends that the proposed monitoring network is inadequate, relying on repurposed water-supply wells rather than strategically placed monitoring wells, and lacks essential analytical testing for carcinogens and radioisotopes.

• The Environmental Impact Assessment (EIA) contains significant geologic discrepancies and lacks site-specific structural geology, borehole logging, and geophysical data from Cluster 1 wells, making it impossible to accurately project natural gas and groundwater migration pathways.
• Tetra4 has failed to produce a valid conceptual site model (CSM) and has created an unreliable groundwater equipotential map for the Karoo aquifer system using data from pumping wells of unknown construction.
• The computer groundwater-flow model for the Karoo aquifer is considered suspect and fundamentally flawed because it treats the system as a simple-porosity intergranular system, ignoring the predominance of flow through fractures and manmade discontinuities like mine voids.
• Simulations of total dissolved solids (TDS) and methane contamination likely understate the risks to water-supply wells; TDS pollution is projected to increase from ~414 hectares of Karoo aquifer at 20 years to ~1,456 hectares at 120 years, while methane pollution is projected to increase from ~163 hectares to ~644 hectares in the same period.
• The proposed groundwater monitoring network is inadequate because it relies on repurposed water-supply wells (WSWs) of unknown construction rather than intentionally designed monitoring wells, and it employs 'micropurge' sampling which may miss contaminated water from multiple fractures.
• The groundwater monitoring plan lacks critical laboratory analytes for health hazards and radioisotopes, specifically hexavalent chromium (Cr+6), thorium, and other radiological species.
• There is no specific remediation response plan for detected groundwater contamination, and while there is a plan to plug new production wells, there is no plan to plug the thousands of existing boreholes that act as migration pathways.

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} }