JB-10-BI-20003
Varanus Island Compression and Power Optimisation Project – Bridging Document to the Varanus Island Hub Operations Environment Plan
PROJECT / FACILITY Varanus Island Hub
REVIEW INTERVAL (MONTHS) No Review Required
SAFETY CRITICAL DOCUMENT NO
Any hard copy of this document, other than those identified above, are uncontrolled. Please refer to the Santos Offshore Business Document Management System for the latest revision.
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Rev Rev Date Author / Editor Amendment
A 04/10/2019 Santos Issued for internal review
Bridging Document issued to DMIRS as a public 0 01/11/2019 Santos document, minus cover page signatory names and environmental workshop attendance list
Bridging Document re-issued to DMIRS as a public 1 05/12/2019 Santos document, minus cover page signatory names and environmental workshop attendance list
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Contents 1 Introduction 5 1.1 Overview 5 1.2 Purpose 5 1.3 Proponent 5 2 Project History 6 3 Regulatory Environmental Approvals 6 4 Existing Environment 7 4.1 Regional Setting 7 4.2 Physical Environment 8 4.3 Biological Environment 9 4.4 Social Environment 15 5 Location 17 6 Project Description 17 6.1 Overview 17 6.2 Description of VICPOP in Operation 18 6.3 Key Scopes and Activities 22 6.4 Transport of VICPOP Components 22 6.5 Greenfields Scope 22 7 Schedule 23 8 Risk Assessment Process 24 9 Risk Assessment 24 9.1 Overview 24 9.2 Air Emissions 24 9.3 Artificial Light 28 10 Consultation 35 11 Implementation Strategy 35 12 Reporting and Recording 35 14 References 36
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List of Figures Figure 4-1: VICPOP Works Location on Varanus Island and Turtle Nesting Beaches 12 Figure 4-2: Protected Migratory Bird Species Nesting Sites on VI 14 Figure 4-3: Regional Marine Habitats and Conservation Reserves 16 Figure 6-1: Location of the VICPOP on Varanus Island 19 Figure 6-2: VICPOP Process Facility General Arrangement 20 Figure 6-3: VICPOP Greenfields Work on Varanus Island 21 Figure 6-4: View showing Compressor Modules, Gas Turbine Generator and Utilities 21
List of Tables Table 4-1: Conservation Significant Fauna Species Potentially Occurring on VI or Surrounding Waters 9 Table 7-1: Indicative Schedule of VICPOP Work Scopes and Activities 24 Table 9-1: Calculated Air Emissions from VICPOP Turbine Driven Machines under Routine Operating Conditions 25
List of Appendices Appendix 1 – VICPOP Scope and Applicability to Relevant Approvals Documents 37 Appendix 2 – Santos WA Risk Matrix 40 Appendix 3 – Gap analysis between VI Hub Operations EP and proposed VICPOP hazards/activities 41 Appendix 4 – Varanus Island Emission Points to Air 44 Appendix 5 – Sign Attendance Sheet for VICPOP Review Activity 46
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1 Introduction
1.1 Overview Santos WA Energy Limited (Santos WA) operates the Varanus Island (VI) Hub oil and gas facilities on the North West Shelf, Western Australia (WA). In order to extend the life of the existing offshore John Brookes (JB) gas field, Santos WA intends to install on VI additional inlet gas compression equipment (referred to as the “process facilities”), electrical power generation, and an electrical switch room, battery room, transformers and instrument air (collectively referred to as the “ancillary facilities”). Together these components are referred to as the Varanus Island Compression and Power Optimisation Project (VICPOP; previously known as the Varanus Island Compression Project or VICP). Presently gas and associated liquids flow under natural pressure from the wellhead platform through the onshore John Brookes (JB) slug catcher then to the inlet of the amine trains on VI. Declining JB reservoir pressure means that in the future there will no longer be sufficient natural pressure to maintain the required production flow rate. The VICPOP will compensate for the future decline in reservoir pressures.
1.2 Purpose Santos WA herewith submits a Bridging Document (BD) to the Varanus Island Hub Operations Environment Plan (VI Hub Operations EP) (EA-60-RI-00186), Revision 6, in line with the Petroleum Pipelines Act 1969 and Petroleum Pipelines (Environment) Regulations 2012 as part of the ongoing operations on VI. Under this BD, as part of operational activities undertaken on PL12 and PL29, Santos WA proposes to install and commission on VI the VICPOP process, electrical power generation and ancillary facilities extending from the existing East Spar (ES) gas plant. The purpose of this BD is to also fulfil the requirement of condition 7 of Pipeline Licence PL12, administered under the Petroleum Pipelines Act 1969. Santos WA, as Licensee, is required to have an approved Construction Environmental Management Plan (CEMP) in place prior to the construction of any approved additions or alterations of the licenced pipeline or any repair or renewal works relating to the Licenced Pipeline that may have a significant impact on the environment. Therefore this BD describes the activities and environment values of VI and surrounding waters, identifies potential environmental risks and impacts that are associated with the activities and not described in the VI Hub Operations EP, outlines control measures to reduce risks and impacts to levels that are environmentally acceptable and as low as reasonably practicable (ALARP), and describes an implementation strategy to deliver a high level of environmental performance.
1.3 Proponent
Santos WA is the proponent for the VICPOP. Contact details for the proponent are as follows: Gareth Bamford Production Offshore Manager Gas Assets Santos Limited, Level 7, 100 St Georges Tce, Perth WA 6000 Ph: 6218 7139 Email: [email protected]
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2 Project History
The VICPOP is the continuation of a previously sanctioned and substantially completed project known as the VICP, as described below. VICP works commenced in September 2013, and the following construction activities were completed by June 2014: + Bulk earthworks including construction of a perimeter bund surrounding the VICP works area (Figure 6-2). + Stormwater drainage system. + Northern section of the VICP access road to west laydown area. + Closed drain system. + Support foundations for the electrical room and C40 gas turbine generator. + Support foundations for the inlet compression modules, and partial rock-bolting. + Installation of the earthing grid commenced, but not completed. + Kitchen Mess and Crib Room (KMCR). + West Wharf upgrade. + Fabrication of the process modules and transport to Henderson. These works were managed in accordance with the VI CEMP (JB-10-RI-002, Revision 5) as accepted by the Department of Mines and Petroleum (now the Department of Mines, Industry Regulation and Safety; DMIRS) on 27-Aug-13. In circa June 2014, the project was suspended and deferred for commercial reasons. Following project deferment, the VI Hub Operations EP was updated to include the completed VICP works and the VICP operational lighting requirements. The updated VI Hub Operations EP was accepted by DMIRS on 28- Sep-14. On 26-Aug-18, the VI CEMP expired and is no longer in-force. On 01-Jul-19, planning for the completion of VICP commenced, with the project renamed VICPOP. A Written Notification (WN) (JB-10-RI-20002.1) was submitted to DMIRS, in accordance with the Petroleum Pipelines (Environment) Regulations 2012, to conduct VICPOP preparatory works and was accepted by DMIRS on 16-Sep-19. An overview of the preparatory works is provided in Appendix 1. The remainder of the VICPOP works will be managed in accordance with this BD and the regulatory environmental approvals described below.
3 Regulatory Environmental Approvals
In addition to this BD, the following regulatory environmental approvals are relevant to VICPOP: + Pipeline Licence PL12, condition 7, administered under the Petroleum Pipelines Act 1969, requires the Licensee to have an approved Construction Environmental Management Plan (CEMP) in place prior to the construction of any approved additions or alterations of the licenced pipeline or any repair or renewal works relating to the licenced pipeline that may have a significant impact on the environment. This BD fulfils the requirements of condition 7, and is directly linked to the in-forced revision of the VI Hub Operations EP. + VI Hub Operations EP. On submission of this BD, the VI Hub Operations EP five-year revision was under assessment by DMIRS. Once the plan is accepted by DMIRS, this BD will be reviewed to ensure all environmental impacts and risks remain at levels that are acceptable and ALARP. In addition, minor amendments to the VI Hub Operation EP will be required to ensure VICPOP operations are appropriately described and accounted for. Resubmission to DMIRS for acceptance will be completed prior to sustained operations. + A Written Notification (JB-10-RI-20002.1) was submitted to DMIRS for VICPOP preparatory works, in accordance with the Petroleum Pipelines (Environment) Regulations 2012. The WN was accepted by DMIRS on 16-Sep-19. These works have commenced. + The VI operations are a ‘prescribed premise’ as defined under Part V of the WA Environmental Protection Act 1986 (EP Act). Santos WA holds a Part V operating licence (L6284/1992/10) covering
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the VI facilities and the Harriet Oil Field. The conditions of the licence focus on setting limits on discharges of waste and emissions to the environment, monitoring discharges and the impact on the environment and reporting the results of the monitoring to Department of Water and Environmental Regulation (DWER). A Works Approval Application (JB-10-BI-20002) for the installation and commissioning of VICPOP was submitted to DWER on 20-Sep-19 in accordance with section 53 of the EP Act. A Licence Amendment Application for VICPOP will be submitted prior to the operation of the facility. + A section 38 referral under Part IV of the EP Act was submitted for VICP to the Office of the Environmental Protection Authority (EPA) and a decision of “not assessed – Public Advice Given” was determined on 13-Mar-13. No further environmental assessment for VICPOP is required under Part IV as the original assessment was deemed by Santos WA to be valid and current. Existing Ministerial Statements under Part IV of the EP Act are described in Section 2.2.4 of the VI Hub Operations EP. + VICP was referred to the Commonwealth Department of Sustainability, Environment, Water, Population and Communities (SEWPaC; now the Department of the Environment and Energy) on 21-Dec-12, under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). Separate referrals were made for the preparatory works (earth works) and installation works. The referral decisions for both (EPBC 2013/6900 and EPBC 2013/6952 respectively) were determined to be “not controlled action if undertaken in a particular manner”. Applicable referral commitments and EPBC conditions have been incorporated into this BD. No further environmental assessment under the EPBC Act is required for VICPOP as the original assessment was deemed by Santos WA to be valid and sufficient. EPBC approvals are described in Section 2.2.5 of the VI Hub Operations EP. + Leases 1902 and 2064, clause 24(a), administered under the Conservation and Land Management Act 1984, requires that “the Lessees shall develop a Lighting Management Plan as a part of the EP or as a separate document”. Section 4.1.1 of the VI Lighting Management Plan (VILMP) (EA-60-RI- 00153, revision 9) requires that “An activity-specific Illumination Plan is developed at the detailed design stage of a new project or activity. Each light source is described in terms of its purpose, location, footprint, intensity and spectral composition”. Lighting will be managed in accordance with VICP Process Facility Outdoor Illumination Plan (JB-10-RE-00044) which has been developed in accordance with the VILMP. Further details on existing VI regulatory approvals are detailed in Section 2.2 of the VI Hub Operations EP.
4 Existing Environment
4.1 Regional Setting VI is located in the North-west Marine Region within the Northwest Shelf Province. This region is characterised by shallow-water tropical marine ecosystems with high species richness. Most of the region’s species are tropical and are also found in other parts of the Indian and western Pacific oceans. The southern part of the region is a transition zone between tropical and temperate waters and includes the northern extent of the ranges of some temperate species that are more typical of the South-west Marine Region. High diversity is partly driven by the interaction between seafloor features and the currents of the region. The interaction of seafloor features and oceanographic processes also supports unique ecosystems and associated trophic interactions and communities (SEWPaC, 2012). Key features of the North-west Marine Region are the Ningaloo Reef and North West Cape to the southwest of VI, the Montebello/Barrow/Lowendal islands around VI and the Dampier Archipelago/Burrup Peninsula to the east of VI. Barrow Island, the Lowendal Islands (including VI) and the Montebello Islands are part of a shallow submarine ridge, which extends north from the mainland near Onslow. The ridge contains extensive areas of intertidal and shallow subtidal limestone pavement surrounding the numerous, mostly small
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islands which are found in the region. The seabed is primarily less than 5 m deep and consists of sand veneered limestone pavement with patches of fringing coral reef. Varanus Island is also situated in the Interim Biogeographic Regionalisation for Australia (IBRA) Carnarvon Biogeographic region, within the Cape Range subregion (CAR1). In addition to the mainland area surrounding Cape Range, key values of this subregion include Exmouth Gulf Islands, Murion Islands, Lowendal Islands, Montebello Islands and Barrow Island.
4.2 Physical Environment
Varanus Island is in the arid tropics characterised by high summer temperatures, periodic cyclones and associated rainfall. Rainfall in the region is generally low with evaporation exceeding rainfall throughout the year. Intense rainfall may occur during the passage of summer tropical cyclones and thunderstorms. The summer and winter seasons fall into the periods September–March and May–July, respectively. Winters are characterised by clear skies, fine weather, predominantly strong east to south-east winds and infrequent rain. Summer winds are more variable, with strong south-westerlies dominating. Three to four cyclones per year are typical, primarily between December and March. The major geo-morphological feature of the region is the North West Shelf (NWS). The NWS, including the continental shelf and the marginal platforms and plateaus, extends from North West Cape to the Northern Territory border and out to the 2,000 m isobath. The dominant component of the NWS is the Rowley Shelf which comprises extensive cemented calcareous sediments (limestone) which forms a shallow, gently inclining seabed extending from the coast to some 40 km offshore where water depths reach 20 m. Sands derived from the erosion of the limestone and biological remains blanket the submarine Rowley Shelf in variable amounts. Emergent islands, cays and reef structures locally interrupt the gently sloping seabed. Barrow Island, Montebello Islands and the Lowendal Islands are the furthest offshore islands on the Rowley Shelf. Seaward of the Rowley Shelf the substrate slopes towards the edge of the Continental Shelf. The mid continental shelf region (nominally between the 30 m and 100 m isobaths) is characterised by a thick sequence of carbonate rock that is overlain by thin layers of unconsolidated fine to medium grained, carbonate sediments with occasional shell or gravel patches. Regional surveys on the NWS indicate the seafloor composition is uniform throughout the area, but with spatial variation in the grain size and origin of the surface sediments. Surface sediments in the area are predominantly composed of skeletal remains of marine fauna, with lenses of weathered sands. Regionally, the seafloor tends to be flat unconsolidated and sedimentary with occasional calcarenite rock outcrops. Nearshore waters along the mainland coast are often characterised by seaward berms, or chenniers, that are frequently broached by tidal channels. Limestone and mobile sand shoals dominate the waters between the mainland and the coastal island chains as well as between the islands themselves. The Lowendal group of islands are low lying limestone rock, some covered in vegetation, others being rock with few plants to be found. The formation is comprised of lime-cemented dune sand that was deposited during the Pleistocene period. Shoreline profiles for the Lowendal group of islands are typically steep, and contain relatively narrow low intertidal zones, which dip onto the extensive shallow subtidal platform that characterises the area. Both the lower intertidal and shallow subtidal zones comprise semi-planar limestone pavement. Shoreline/intertidal habitats surrounding VI are described as rocky undercut cliffs and intertidal limestone platforms, large sandy beaches with back dunes and mangroves (on the western beaches). Shallow subtidal habitats surrounding VI are described as limestone pavements and reefs, isolated corals and coral bommies offshore. The topography of VI is flat to undulating low dunes. The elevation ranges from sea level to a maximum of 18 m Australian Height Datum (AHD). Outcropping occurs over much of the lease area at VI, particularly in the eastern and south-eastern areas.
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4.3 Biological Environment The Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) lists threatened and migratory fauna species that are protected under Commonwealth legislation and various international conventions and treaties. A search of the EPBC Act Protected Matters Database was conducted using a 10-km radius search area from a central location coordinate on VI. The search identified 19 listed threatened fauna species potentially occurring on VI or within the surrounding waters, the majority of which are also listed as migratory species. An additional 40 species were listed as migratory species. These species, together with their respective conservation status under the WA Biodiversity Conservation Act 2016 (BC Act) and WA Wildlife Conservation (Specially Protected Fauna) Notice 2018 are summarised in Table 4-1.
Table 4-1: Conservation Significant Fauna Species Potentially Occurring on VI or Surrounding Waters
BC Act Common Name Scientific Name EPBC Act Status Status Sharks & Rays Threatened – Vulnerable, Dwarf Sawfish Pristis clavata None Migratory Marine Giant Manta Ray Manta birostris Migratory Marine None Threatened – Vulnerable, Green Sawfish Pristis zijsron Schedule 2 Migratory Marine Grey Nurse Shark Carcharias taurus Threatened – Vulnerable Schedule 3 Narrow Sawfish Anoxypristis cuspidata Migratory Marine None Reef Manta Ray Manta alfredi Migratory Marine None Threatened – Vulnerable, Whale Shark Rhincodon typus Schedule 6 Migratory Marine Threatened – Vulnerable, White Shark Carcharodon carcharias Schedule 3 Migratory Marine Marine mammals Threatened – Blue Whale Balaenoptera musculus Endangered, Migratory Schedule 2 Marine Bryde’s Whale Balaenoptera edeni Migratory Marine None Dugong Dugong dugon Migratory Marine Schedule 7 Threatened – Vulnerable, Humpback Whale Megaptera novaeangliae Schedule 6 Migratory Marine Indo-Pacific Humpback Tursiops aduncus Migratory Marine None Dolphin Killer Whale Orcinus orca Migratory Marine None Spotted Bottlenose Dolphin (Arafura/Timor Tursiops aduncus Migratory Marine None Sea populations) Marine reptiles
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BC Act Common Name Scientific Name EPBC Act Status Status Threatened – Vulnerable, Green Turtle Chelonia mydas Schedule 3 Migratory Marine Threatened – Vulnerable, Flatback Turtle Natator depressus Schedule 3 Migratory Marine Threatened – Vulnerable, Hawksbill Turtle Eretmochelys imbricata Schedule 3 Migratory Marine Threatened – Leatherback Turtle Dermochelys coriacea Endangered, Migratory Schedule 3 Marine Threatened – Loggerhead Turtle Caretta caretta Endangered, Migratory Schedule 2 Marine Threatened – Critically Short-nosed Seasnake Aipysurus apraefrontalis Schedule 1 Endangered Birds Threatened – Australian Painted-snipe Rostratula australis Schedule 2 Endangered Australian Fairy Tern Sternula nereis nereis Threatened – Vulnerable Schedule 3 Barn Swallow Hirundo rustica Migratory Terrestrial Schedule 5 Bridled Tern Sterna anaethetus Migratory Marine Bird Schedule 5 Caspian Tern Sterna caspia Migratory Marine Bird Schedule 5 Common Greenshank Tringa nebularia Migratory Wetland Schedule 5 Common Noddy Anous stolidus Migratory Marine Bird Schedule 5 Common Sandpiper Actitis hypoleucos Migratory Wetland Schedule 5 Crested Tern Thalasseus bergii Migratory Wetland Schedule 5 Threatened – Critically Curlew Sandpiper Calidris ferruginea Endangered, Migratory Schedule 1 Wetland Threatened – Critically Numenius Eastern Curlew Endangered, Migratory Schedule 5 madagascariensis Wetland Fork-tailed Swift Apus pacificus Migratory Marine Bird Schedule 5 Grey Wagtail Motacilla cinerea Migratory Terrestrial Schedule 5 Lesser Frigatebird Fregata ariel Migratory Marine Bird Schedule 5 Osprey Pandion haliaetus Migratory Wetland Schedule 5 Pectoral Sandpiper Calidris melanotos Migratory Wetland Schedule 5 Threatened – Red Knot Calidris canutus Endangered, Migratory Schedule 2 Wetland Roseate Tern Sterna dougallii Migratory Marine Bird Schedule 5
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BC Act Common Name Scientific Name EPBC Act Status Status Threatened – Southern Giant-Petrel Macronectes giganteus Endangered, Migratory Schedule 5 Marine Bird Sharp-tailed Sandpiper Calidris acuminata Migratory Wetland Schedule 5 Streaked Shearwater Calonectris leucomelas Migratory Marine Bird Schedule 5 Wedge-tailed Shearwater Puffinus pacificus Migratory Marine Bird Schedule 5 Yellow Wagtail Motacilla flava Migratory Terrestrial Schedule 5
Schedule 1 Fauna that is rare or is likely to become extinct as critically endangered fauna Schedule 2 Fauna that is rare or is likely to become extinct as vulnerable fauna Schedule 3 Fauna that is rare or is likely to become extinct as vulnerable fauna Schedule 5 Migratory birds protected under an international agreement Schedule 6 Fauna that is of special conservation need as conservation dependant fauna Schedule 7 Other specially protected fauna
The VICPOP works as described within this BD are entirely land-based with little to no potential to impact on the surrounding marine waters, other than those directly adjacent to the island. As such, impacts on marine fauna which are largely offshore species are considered to be negligible. The North-west Marine Region supports globally significant breeding populations of green, hawksbill, loggerhead and flatback turtles (SEWPaC, 2012). The most common species of turtle found nesting on VI is the hawksbill turtle. Flatback turtles are also frequently seen while green turtles are the least common. In an assessment of the preferred nesting beaches on VI conducted in 2019 (Pendoley, 2019b), hawksbill turtle nesting activity was notably higher on Pipeline Beach compared to other monitored beaches, and individuals showed high site fidelity to this beach. Flatback turtle nesting activity was high on Pipeline Beach and Harriet Beach but showed higher site fidelity to Harriet Beach and Tanny’s Beach. Figure 4-1 indicates the marine turtle nesting sites on VI.
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Figure 4-1: VICPOP Works Location on Varanus Island and Turtle Nesting Beaches
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In addition to the EPBC Act-listed species, various other terrestrial fauna and flora occurs on VI. Habitat types most likely to harbour short-range endemic (SRE) invertebrates on VI include sand dunes, limestone plains and mid-island basins. Two confirmed (Rhagada plicata and Quistrachia montebelloensis) and one likely (Aname ‘MYG079’) SRE invertebrates occur in the proposed works areas. All three species were recorded within and outside of the Santos WA lease area. No subterranean fauna surveys have been conducted to date on VI. In the absence of systematic surveys, the likely presence and distribution of troglofauna and stygofauna on VI has been assessed based on the geology of VI and corresponding geologies on Barrow Island, which support subterranean fauna (Phoenix, 2012). VI is comprised of a single geological type described as Pleistocene coastal limestone covered by lime-cemented shelly sand, dune sand and beach conglomerate. This geology is well represented on the eastern side of Barrow Island where extensive subterranean fauna, both troglofauna and stygofauna, has been recorded. It is therefore likely that both troglofauna and stygofauna are present on VI (Phoenix, 2012). The potential extent of troglofauna and stygofauna habitat is believed to correspond with the extent of the island because of the uniformity in geology across the island (Phoenix, 2012). Hence, if troglofauna and stygofauna are present within the Santos WA lease area, they are also likely to be present elsewhere on VI. The Lowendal islands have a diverse avifauna comprising of 89 recorded species, compared with 70 species of the Montebello Islands and 112 species at Barrow Island. At least 64 species of birds feed and nest on the surrounding waters and islands within the Barrow/Montebello/Lowendal island group. The two key groups of birds found on the islands are raptors and seabirds. Of the bird species that are known to breed on VI, the roseate tern (Sterna dougallii) and Australian fairy tern (Sterna nereis) are listed threatened species under the EPBC Act and specially protected fauna under the BC Act. Many of the recorded bird species are migratory and may over-fly the island from time-to-time in transit or while foraging. Santos WA commissioned a survey of the avifauna in November 2012 in relation to bird species potentially affected by the VICPOP works. Of the bird species identified, only the wedge-tailed shearwater (Puffinus pacificus), lesser crested tern (Sterna bengalensis) and bridled tern (Sterna anaethetus) are known to nest in the vicinity of the VICPOP works area (Halfmoon Biosciences, 2012). In a more recent survey undertaken by Pendoley (2019a), the wedge-tailed shearwater was the only species observed nesting in the vicinity of the VICPOP works area. Although the pied cormorant (Phalacrocorax varius) and crested tern (Thalasseus bergii) were recorded nesting on VI, they aren’t considered to be in close proximity to the VICPOP works area (refer to Figure 4-2). Figure 4-2 indicates the nesting sites on VI of the three migratory bird species that are protected under the EPBC Act.
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Figure 4-2: Protected Migratory Bird Species Nesting Sites on VI
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The predominant types of vertebrate terrestrial fauna on VI are reptiles, as presented within the Phoenix (2012) literature search that identified thirteen reptile species occurring on VI. No terrestrial vertebrate fauna species of conservation significance have been recorded within the VICPOP works area. There are no native mammals, endemic or introduced, present on VI (Phoenix, 2012). The vegetation of VI is located in the Fortescue Botanical District, which is part of the Eremaean Botanical Province (Beard, 1975). The vegetation of VI is broadly described as ‘desertic’ dominated by hummock grasslands (Triodia spp). The mangrove species Avicennia marina is present on VI, although its occurrence is very restricted. Santos WA conducts annual mangrove health monitoring on VI. A total of 122 species have been recorded on VI and Bridled Islands (Astron, 2009). No Wildlife Conservation (Rare Flora) Notice 2018 listed threatened (critically endangered, endangered or vulnerable) flora are known to occur on the islands. Eight flora species have very restricted distributions on VI and are considered locally significant (Astron, 2009). Fourteen weed species and eight introduced mainland species have been recorded on VI since 2000 (Astron, 2011).
4.4 Social Environment The main population centres in the region are the towns of Dampier, Karratha and Port Hedland. Smaller coastal and fishing towns are Exmouth, Onslow and Point Samson. The nearest population centers to VI are Onslow and Dampier, located approximately 110 km to the south-southwest and approximately 120 km to the west respectively. VI is part of the Lowendal Islands Nature Reserve (Reserve 33902) and is managed by Department of Biodiversity, Conservation and Attractions (DBCA). All petroleum activities on VI are managed in accordance with leases 1902/100 and 2604/100 the Pipeline Licences PL12 and PL29, and variations thereto. VI and the marine areas of the port are excluded from any marine reserves. The nearest state marine reserves are the Barrow Island Marine Management Area and Montebello Islands Marine Park as indicated in Figure 4-3. No Aboriginal ethnographic or archaeological sites are known for VI and no records of Aboriginal occupation have been recorded for VI or the surrounding marine waters. There are no Native Title claims that exist over VI or the offshore facilities that connect to the VI facilities. There are no shipwrecks located in the immediate vicinity of VI. Commercial fisheries will not be affected by the vessel-based activities required for the proposed petroleum activities. Tourism in the areas surrounding VI is limited to nature-based tourism in the adjacent marine reserves. Tourism and recreational activities in the local area include SCUBA diving, snorkelling, fishing, mud crabbing, wildlife appreciation, island exploring and a limited amount of surfing. Visits to Barrow Island and VI are rare due to managed access restrictions. Chevron-operated oil and gas production facilities are also located on Barrow Island, located approximately 20 km southwest of VI.
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Figure 4-3: Regional Marine Habitats and Conservation Reserves
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5 Location
The location of the VICPOP works area is shown in Figure 6-1. The VICPOP has the following key areas which are shown in Figure 6-2: + Greenfields Area (VICPOP works area) – Reclaimed bund area (herein referred to as the VICPOP “works area” as shown in isometric view in Figure 6-3 and Figure 6-4) where the new process, power generation and ancillary facilities will be installed. The area is approximately a 1 hectare cleared plate area and is accessed from the south western corner via the VICPOP access road, which connects the VICPOP laydown area and site offices. + Brownfields Area – Tie-in points within a number of areas in the existing ES gas plant. + Process Battery Limit – Location where the process piping connections are made between the new plant and existing ES gas plant. + Utility Battery Limit – Location where utility piping and electrical tie-ins cross between the new plant and existing ES gas plant. + East Spar Gas Plant – The existing hydrocarbon production facility comprising gas dehydration and HC dew pointing trains, CO2 removal trains, condensate stabilisation and utilities that the new plant interfaces. + VICPOP Laydown Area – Area allocated to perform “off plot” activities to support the works.
6 Project Description
6.1 Overview The VICPOP involves the planning, design, delivery, installation, pre‐commissioning, function testing, commissioning and operation of new process, power generation and ancillary facilities extending from the existing ES gas plant. The separate components of the VICPOP include: + Two Solar Mars 100 gas turbine driven compressors, module based and including scrubbers, air cooled heat exchangers, gas/gas exchanger and Joule‐Thompson (JT) gas cooling valve. + One pipe rack module. + One Centaur 40 gas turbine driven electrical power generator. + One electrical switch room. + One transformer compound and battery room. + One instrument air package. + Tie-in of demineralised water, fire water, power and data. The electrical power generator (Centaur 40 gas turbine) is required to meet the load demands of the new facilities and provide sufficient reserve to be shared with the existing plant such that the existing plant generators can effectively backup the VICPOP C40 generator and vice versa. Areas adjacent to the access road (upgraded during preparatory works) (Figure 6-2) will be used as lay down areas for items including closed and open top containers, bulk materials, pallets, pipe spools, cable reels, light fabrication areas, site offices, back‐load items, waste bins, and concrete materials. Additional plant, equipment and temporary facilities will be brought onto VI to support the VICPOP include mobile generators, welders, light vehicles, trucks, site offices etc. The VICPOP process, electrical power generator and ancillary facilities will be delivered to VI via barges. At least two scheduled deliveries will be required. The inlet compressor modules will either be installed directly upon delivery or will be temporarily held within the designated laydown area until required.
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6.2 Description of VICPOP in Operation The JB gas field, as a depletion field with no aquifer drive, has shown a steady and predictable decline during its operating life. A reduced arrival pressure at VI will allow for significant additional recovery of gas from the JB gas field. However any significant reduction in arrival pressure will require booster compression at the inlet to the VI gas processing trains to maintain the current gas export capacity across the VI facilities. VICPOP when operational will maximise the recovery and the deliverability from the JB gas field by allowing for a reduction in the arrival pressure of the gas at VI. JB produced fluids are first processed by the JB slug catcher which is part of the existing ES gas plant. The gas phase outlet of this slug catcher will be re‐routed and instead of going to the CO2 removal plants (amine plant) located in the existing plant the gas will be directed to the inlet compressors located within the new VICPOP process facilities. Within the VICPOP process facilities, wet gas from the JB slug catcher then has further liquids knocked out by inlet compressor scrubbers before then being compressed by inlet compressors. The inlet compressors will discharge gas at temperatures in excess of 100°C therefore compressor discharge coolers are required. Initial cooling of the gas will be achieved via air cooled heat exchangers which will typically drop gas stream temperatures to between 35°C and 55°C depending on the ambient air temperature which has considerable seasonal variation. To assist in further temperature control, the sea bed cooled gas arriving from the JB slug catcher is directed through a gas‐gas exchanger (compressor suction to compressor discharge exchanger) located within the new VICPOP process facilities. This helps to cool the discharged wet gas from the compressors inside the new facilities. After the gas‐gas exchanger the compressed gas is cooled further again by letting it down across a JT valve. This last stage of JT cooling is only enabled as required by an automatic control algorithm, otherwise it is effectively bypassed. The compressed, cooled wet JB gas is then sent via a compressed gas discharge header back to the CO2 removal (amine) plants in the existing ES gas plant. The VICPOP has no requirement for additional produced liquid handling facilities. Produced water will be tied into the existing plant produced water treatment. All water liquids knocked out of the gas in the new VICPOP process facilities are piped into the produced water treatment system located within the existing ES gas plant. The new blowdown and pressure relief systems will be connected to the existing plant flare. The VICPOP process facilities essentially operates between two parts of the existing plant, JB onshore arrival and amine facilities. The VICPOP function is to simply boost the pressure of the arriving JB wet gas so that the downstream amine, gas treatment and sales gas compression plants can all operate without modification.
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Figure 6-1: Location of the VICPOP on Varanus Island
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Figure 6-2: VICPOP Process Facility General Arrangement
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Figure 6-3: VICPOP Greenfields Work on Varanus Island
Figure 6-4: View showing Compressor Modules, Gas Turbine Generator and Utilities
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6.3 Key Scopes and Activities The VICPOP can be distinguished by the following work scopes and activities: + Preparatory works. + Transport of VICPOP process, electrical power generation and ancillary facilities to VI. + Greenfields work within the VICPOP works area (Figure 6-2). These activities include installation of the process, electrical power generator and ancillary facilities, pre-commissioning, function testing and commissioning. + Brownfields work (upgrades and numerous tie-in’s to the existing ES gas plant) (Figure 6-2). + Utilisation of existing VI support services / utilities to support the VICPOP. + Sustained operations. Appendix 1 provides details on the preparatory, greenfields and brownfields works, support services / utilities and sustained operations. The VICPOP scope covered under this BD is described further in the various sections below. The preparatory works and sustained operations are out of scope of this BD, as described in Section 3.
6.4 Transport of VICPOP Components
Sea Transport and Unloading The inlet compression and power generation modules were fabricated at various locations in Southeast Asia (SEA) and transported to Western Australia in 2015. The consolidated modules have been stored at the Australian Marine Complex Common User Facility (AMCCUF) in Henderson, WA since arriving from SEA. The modules and other project equipment to be transported from Henderson to VI West Wharf are described in the greenfields scope within Appendix 1 and Section 6.5. Transport to the West Wharf will be undertaken using a towed barge with at least two deliveries required. The barge deliveries will be landed at West Wharf during daylight hours, making use of favourable tides. De-ballasting will ground the barge vessel until offloading is complete and the tide re-floats the barge vessel. Seabed disturbance will be proportional to the hull area of each grounded barge (approximately 100 m x 30 m). A diver clearance survey is being undertaken to remove any debris such as large rocks. Barges will be moored to the wharf using dead man anchors installed adjacent to the West Wharf as part of the VICPOP preparatory works (refer to WN, JB-10-RI-20002.1). All other materials will be mobilised to and from VI using landing craft as described and managed within the existing VI Hub Operations EP.
Land Transport Land transport of the modules and equipment from the West Wharf to the VICPOP works area will occur via a self-propelled modular trailer (SPMT) using the existing unsealed road between West Wharf and the VICPOP works area (Figure 6-1). The VICPOP components will be transported during daylight hours only.
6.5 Greenfields Scope The greenfields scope of works will be conducted entirely within the VICPOP works area shown in Figure 6-2, Figure 6-3 and Figure 6-4. Works include the installation, pre-commissioning, function testing and commissioning of the components described within Section 6.1 and in the greenfields section of Appendix 1.
Installation Installation activities include: + Transport and installation of process, power generation and ancillary facilities. + Heavy lifting activities.
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+ Assembly of large bore piping. + Large bore cable pulls. + Road paving.
Pre-commissioning Pre-commissioning involves testing of all installed equipment, both mechanical and electrical and instrumentation (E&I). Prefabricated piping has been hydrotested and had non-destructive examination (NDE) conducted prior to delivery to site. Tie-in spools as required for the connection of pressure pipework between the modules and existing plant will be hydrotested on VI as is normal practice. Spool hydrotesting will be undertaken using potable water free of corrosion inhibitors and oxygen scavenging chemicals, and therefore, will not require a controlled disposal method. On completion of spool hydrotesting, the potable water will be released into VI storm water drains. Note that Section 3.2 of the VI Hub Operations EP states that for hydrotesting and isolation of pipelines and production equipment, no BD or Notification of Change is required for this activity.
Function Testing Following pre‐commissioning, individual systems will be function tested to confirm operation, performance and control functions. This phase will require energisation and/or pressurisation of equipment. Function testing includes the introduction of inert gas (no hydrocarbons) to the completed sub-systems for nitrogen leak tests, valve (car sealing and locking), first fills and valve line up. The E&I scope of function testing includes cause and effects testing, software logic checks, communication system checks and instrumentation line-up.
Commissioning Once site installation, pre-commissioning and function testing activities are completed, the VICPOP process, electrical power generation and ancillary facilities, will be commissioned. The purpose of commissioning is to confirm the proper functioning of the VICPOP’s major components and to detect any potential issues so that any adjustments may be made prior to gas production through the VICPOP process facilities. VICPOP commissioning covers the introduction of hydrocarbons and start-up to achieve stable operation. Typically, this will involve: + Nitrogen purging of installed equipment. + Introduction of hydrocarbons. + Pressure testing. + Sampling. + Filter checks. + Performance testing. During the commissioning phase, which is estimated to take no more than 90 days, turbine exhaust stack emission monitoring will be undertaken as per the Part V (EP Act) approvals outlined in Section 3. After 90 days commissioning, the facility will be considered in steady state operations under the VI Hub Operations EP.
7 Schedule
An indicative schedule for the VICPOP work scopes and activities described in this BD is presented in Table 7-1.
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Table 7-1: Indicative Schedule of VICPOP Work Scopes and Activities
Milestone Commencemen Completion t Date Date Transportation 01-Jan-20 Q1 2020 Installation Q1 2020 Q3 2020 Pre-commissioning & function testing Q1 2020 Q1 2021 Commissioning Q4 2020 Q2 2021 Completion of the works - Q2 2021
8 Risk Assessment Process
Environmental risks for the VICPOP were reviewed by Santos WA on 18-Oct-19 (signed review workshop attendance sheet provided in Appendix 5). During the review, environmental risks were assessed by reviewing the activities and events that may or may not occur during the installation, pre- commissioning, function testing and commissioning of the VICPOP. Identified risks were then reviewed against those described within the VI Hub Operations EP and environmental management gaps were identified. The identified gaps are described and addressed in Sections 9.2 and 9.3 of this BD. The risks documented in the VI Hub Operations EP were assessed under the Apache Environmental Risk Identification Procedure (EA-91-IG-00004, revision 0) and Risk Matrix (AE-91-IF-00039, revision 0). These documents have been superseded by the company’s Environmental Hazard Identification and Assessment Procedure (EA-91-IG-00004, revision 4) and Risk Matrix (QE-91-IF-00039, revision 5). The Risk Matrix is provided in Appendix 2. As the updated procedure and matrix have been used for this BD, there are some minor differences in the definitions of risk likelihood, consequence and level between the VI Hub Operations EP and this BD.
9 Risk Assessment
9.1 Overview The environmental management gaps between the VI Hub Operations EP and the proposed VICPOP activities, which are addressed in this BD, relate to the management of air (Section 9.2) and light (Section 9.3) emissions. Importantly, while management gaps exist for these aspects (events) the VICPOP does not introduce and new, or significantly increase any existing, environmental risk or impact. Overall the environmental risks of VICPOP air and light emissions were determined to be ‘low’.
9.2 Air Emissions
Description of the Event
Hazard Planned release of combustion emissions to air. Cause The combustion of fuel gas (natural gas) in the inlet compression gas turbines and the gas turbine generator producing emissions such as oxides of nitrogen (NOX), carbon dioxide (CO2), carbon monoxide (CO), sulphur dioxide (SO2), volatile organic compounds (VOCs), unburnt hydrocarbons (UHC such as methane CH4) and particulate matter (PM10). This will result in the planned release of point source emissions from two compressor turbine exhaust stacks and a gas turbine generator exhaust stack during commissioning and operations.
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Extent Combustion emissions from the process and power generation facilities may disperse to a localised extent. Duration Stack emissions from the process and power generation facilities will be for the duration of VICPOP commissioning and operations.
Potential Impacts
9.2.2.1 Sensitive Receptors
As detailed in Section 6.2.2 of the VI Hub Operations EP. Potential receptors that may be affected from planned release of combustion-related air emissions include: + Terrestrial and marine environment. + Local Santos accommodation camps.
9.2.2.2 Point Source Emissions
The commissioning and operation of two gas fuelled Solar Mars 100 gas turbine driven compressors (10.5 MW each), and one gas fuelled Solar Centaur 40 powered generator (3.5 MW), will cause a change to the volume of atmospheric emissions on VI and will contribute to localised pollutant emissions. Point source emissions from the VICPOP were not addressed in the VI Hub Operations EP and therefore have been assessed in this BD.
VICPOP turbine operations will result in the release of NOX, CO2 and traces of SO2, CO, UHC, VOCs and PM10. Existing VI emission points together with the three additional emission points (24, 25 and 26) are as indicated in Appendix 4. Additional emissions from the VICPOP process equipment under normal operations include combustion emissions from two exhaust stacks associated with the two Solar Mars 100 inlet compressors and combustion emissions from an exhaust stack associated with the Centaur 40 electrical power generator. The point source air emissions from the VICPOP are summarised in Table 9-1.
Table 9-1: Calculated Air Emissions from VICPOP Turbine Driven Machines under Routine Operating Conditions
Source Exit Temp NOX NOX SO2 Rsmog* Velocity (K) (g/s) (mg/Nm3) (g/s) (g/s) (m/s) Power Generator (3.5 MW) 8.8 726 0.84 60 0 0 Centaur 40 Inlet Compressors (10.5 MW) 16.2 772 2.27 70 0 0 Mars 100
(Source: Solar Turbines based on performance runs conducted on 4/06/13 at 11oC ambient) *Rsmog is a summary measure of volatile organic compounds.
The emission values in Table 9-1 were used as the basis of air quality modelling for routine, steady state conditions. Modelling for the existing VI emission sources and additional source emissions arising from the VICPOP’s inlet compressors and electrical power generator was undertaken on behalf of Santos WA by Pacific Environment Limited (PE) (JB-10-RI-014). Although this modelling was undertaken in 2013 for VICP, the plant configuration, emission sources and the National Environment Protection (Ambient Air Quality) Measure (NEPM) standards for NOX remains unchanged. Therefore the modelling of ground level concentrations of NOX remains valid for the VICPOP.
It should be noted that SO2, UHC, CO and PM10 were not modelled due to their very low levels within the turbine flue gas. Likewise, Benzene, Toluene, Ethylbenzene and Xylene (BTEX) arising from fugitive
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emissions within the VICPOP works area was considered to be negligible and therefore not modelled. The modelling report demonstrated that: + The introduction of additional emissions due to the VICPOP turbines will result in an increase of 3 1 μg/Nm (equivalent to 0.4%) in the maximum predicted 1-hour NOX ground level concentration on VI (PE, 2013).
+ The maximum predicted 1-hour ground level concentrations of NOX for both the existing emissions and for emissions including the VICPOP are significantly (13%) lower than the NEMP NOX criteria (PE, 2013).
+ The ground level concentration of NOX attributable to the introduction of the additional emission sources associated with the VICPOP, is predicted to result in an insignificant increase of 0.4 μg/Nm3 (equivalent to 0.6%) in the annual average on VI (PE, 2013).
9.2.2.3 Non-routine Emissions
Non-routine conditions (process upset conditions such as a compressor failure or plant trips, etc.) can lead to significantly increased emissions for short periods of time. In particular, if one or more processing trains must be shut down, then the process gas inventory must be routed to the flares for disposal, leading to high flare emissions. The ES gas plant blowdown takes approximately 15 minutes from high operating pressure to safe low levels. Where possible, the occurrence of continuous flaring and venting is avoided. The flaring condition was not addressed in the VICPOP Air Quality Assessment (JB-10-RI-014) since the ES gas plant is an existing facility and the emissions from upset conditions will not change with the VICPOP as there is no increase in production capacity. Emission levels via the existing ES flare system will be only slightly elevated due to the relatively small containment volumes within the VICPOP process pipework. Function testing and pre-commissioning of the VICPOP process and power generation facilities prior to the introduction of hydrocarbons significantly reduces the likelihood of an unplanned release of hydrocarbons to air.
Pre-treatment Risk
Likelihood Consequence Ranking Probable Minor Without controls in place, air Combustion emissions could potentially exceed pollutants could be released at regulatory targets set to minimise harm to the levels with the potential to affect environment and human receptors. environmental and human VICPOP emission volumes will be relatively small in receptors. relation to existing atmospheric emissions on VI. The highly dispersive nature of the North West Shelf Medium suggests that air emissions will disperse quickly and a significant impact to sensitive receptors is not expected. The local camps are managed and occupied by Santos, and public access to the lease area is restricted.
The following inherent design controls to reduce atmospheric emissions to ALARP during commissioning and operation of the turbine powered equipment (Solar Mars 100 compressors and Centaur 40 generator) include the following: + Low sulphur fuel (<8 ppm) to be used for the turbines.
+ Selection of dry-low NOX burners within each turbine using Solar Turbines proprietary SoLoNOx technology to reduce NOX (as NO2) combustion emissions.
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+ Specification of flue gas monitoring points for the turbine powered machines (point source monitoring emission monitoring to verify machine performance meets emission targets). + Selection of rotating machinery such that the load characteristics for the machines are predominantly elevated thus facilitating performance of the SoLoNOx technology. + High utilisation (>95% annually) for operation of the turbine powered machinery thereby reducing increased emissions that may be expected during non-steady state conditions (start-up and shut- down). + Selection of compressor and generator engines as turbine equipment that have intrinsically high combustion temperatures resulting in reduced CO (<50 ppm), unburnt hydrocarbons (UHC) (<25 ppm) and particulate emissions as flue gas. + Selection of electric starters for the three turbines rather than a pneumatic (i.e. fuel gas) alternative. Control measures that will be implemented to manage the release of combustion emission to air are provided in Section 9.2.4.
Measurement of Environmental Performance
Environmental Hazard Release of combustion emissions to air during VICPOP commissioning and operation. Performance Objective Air emissions in compliance with emission targets. Performance Standard Measurement Criteria Responsible Person VICPOP facilities will be Compliance Report submitted to DWER VICPOP Project installed and commissioned demonstrates that VICPOP facilities have Manager in accordance with the Part been installed in accordance with the V Works Approval. Works Approval. Commissioning Report submitted to DWER demonstrates that commissioning air quality targets have been achieved.
Post-treatment Risk
Likelihood Consequence Ranking Unlikely Negligible With controls in place, air Combustion emissions will be below regulatory targets pollutants are unlikely to be set to minimise harm to the environment and human released at levels that receptors. Air quality monitoring will ensure that these Low would affect environmental targets are met. and human receptors. Selection of SoLoNOx technology ensures that air emissions are as low as reasonably practicable.
Demonstration of ALARP Best practice pollution abatement technology (e.g. SoLoNOx technology) has been selected for use in the VICPOP process equipment. Emission reduction measures, together with performance monitoring (stack emissions testing), demonstrates that all practicable management measures have been implemented. The air quality modelling for the additional source emissions arising from the VICPOP demonstrated that the adopted pollutant abatement technology would result in an insignificant increase in the average annual air emissions on VI. The high cost of implementing post combustion, add-on emissions control (such as selective catalytic reduction), in an attempt to achieve single digit NOx emissions was evaluated as being grossly disproportionate to the low environmental benefit (post-treatment risk is already low).
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Acceptability Evaluation The environmental risk of VICPOP air emissions was assessed as ‘low’, which according to the Santos WA risk framework is environmentally acceptable. A detailed acceptability evaluation is provided below.
Is the consequence ranked as A or Yes – Maximum consequence from atmospheric emissions B? is A (Negligible). Is further information required in the No – Potential impacts and risks are well understood consequence assessment? through the information available, and existing operations. Are risks and impacts consistent with Yes – Activity evaluated in accordance with Santos WA’s the principles of ESD? Environmental Hazard Identification and Assessment Procedure which considers principles of Ecological Sustainable Development (ESD). Are performance standards Yes – The expected point source air emissions meet the consistent with industry standards, targets defined in the NSW Protection of the Environment legal and regulatory requirements, Operations (Clean Air) Regulations 2010. Air emissions including protected matters? modelling has demonstrated that ambient air quality is expected to meet the NOx criteria determined by the National Environmental Protection Measure for Ambient Air Quality. Air emissions are regulated and managed via DWER, and Santos WA will comply with the VICPOP Works Approval. Are risks and impacts consistent with Yes – Aligns with Santos WA Environmental Management Santos WA Environmental Policy. Management Policy? Are risks and impacts consistent with Yes – No stakeholder concerns have been raised stakeholder expectations? regarding this aspect. Are performance standards such that Yes – See ALARP above. the impact or risk is considered to be ALARP?
9.3 Artificial Light
Description of the Event
Hazard Light spill affecting fauna, specifically breeding marine turtles and seabirds. Cause Lighting required for delivery, transport, installation, pre-commissioning, function testing, commissioning and operation of the VICPOP process, electrical power generation and ancillary facilities. Extent Potential for direct light spill and indirect light glow affecting wedge-tailed shearwater rookeries and turtle nesting beaches on VI. Duration Duration of VICPOP (Section 7). Post-commissioning, artificial lighting will be managed in accordance with the VI Hub Operations EP.
Potential Impacts
9.3.2.1 Sensitive Receptors
Continuous lighting emanating from the same location for an extended period of time may result in alterations to the behaviour of sensitive receptors on VI which are marine turtles and seabirds. Disturbance may include:
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+ Turtles and turtle hatchlings may be misoriented and disoriented by lights. + Seabirds may either be attracted by the light source itself or indirectly due to marine fauna prey (e.g. fish and invertebrates) attracted to light. Additional detail is provided in Section 6.3.2 of the VI Hub Operations EP. Marine Turtles Varanus Island and the surrounding marine environment is mapped as ‘habitat critical (nesting)’ for green (Chelonia mydas), hawksbill (Eretmochelys imbricata) and flatback (Natator depressus) turtles (DoEE, 2017). The nesting habitat on VI for these species is shown in Figure 4-1. Turtle breeding activities on VI are well documented through the implementation of an annual Turtle Monitoring Programme (Varanus and Airlie Island Turtle Monitoring Method Statement; EA-00-RI-10058.03). The most common turtle species nesting on VI is the hawksbill turtle, however, flatback turtles are seen frequently whilst green turtles are the least common. The hawksbill and flatback turtle peak nesting season is defined as the period from 1 October to 1 February of each year (EPBC 2013/6952). Light pollution is highlighted in the Recovery Plan for Marine Turtles in Australia: 2017-2027 (DoEE, 2017) and the draft National Light Pollution Guidelines for Wildlife Including Marine Turtles, Seabirds and Migratory Shorebirds Commonwealth of Australia 2019 (DoTEE, 2019) as a factor requiring management for successful marine turtle nesting. The most significant risk posed to marine turtles from artificial lighting is the potential disorientation of hatchlings following their emergence from nests, although breeding adult turtles can also be disoriented (Rich and Longcore, 2006 in EPA 2010). Once in the ocean, hatchlings are thought to remain close to the surface, orient by wave fronts and swim into deep offshore waters for several days to escape the more predator-filled shallow inshore waters. During this period, light spill from coastal port infrastructure and ships may ˋentrap’ hatchling swimming behaviour, reducing the success of their seaward dispersion and potentially increasing their exposure to predation via silhouetting (Salmon et al., 1992). The Recovery Plan for Marine Turtles in Australia states that light pollution is of high risk to hawksbill (WA genetic stock), flatback (Pilbara genetic stock) and green (North West Shelf genetic stock) turtles (DoEE, 2017). Specifically, the plan indicates that artificial light may reduce the overall reproductive output of a stock, and therefore recovery of the species, by: + Inhibiting nesting by females. + Disrupting hatchling orientation and sea finding behaviour. + Creating pools of light that attract swimming hatchlings and increase their risk of predation. All three species nesting on VI are classified as threatened under the EPBC Act and the WA Biodiversity Conservation Act 2016. On a regional scale, VI is not a key flatback or green turtle rookery. However, it is considered one of only a few hawksbill rookeries in Western Australia. Figure 4-1 shows the turtle nesting beaches on VI. Pipeline Beach is the main nesting beach for hawksbill turtles and Tanny’s Beach is the primary flatback nesting beach. Cliff and Cook beaches are the only two turtle nesting beaches on VI that are not within close geographical proximity (within 1 km) to the proposed VICPOP works area. VI Hub lights are visible from Anderson, Tanny’s, Harriet and Pipeline beaches. Despite this, turtles have been recorded successfully breeding on VI over the last 20 years with an estimated survival probability of over 94% (Prince and Chaloupka, 2011). This would indicate that the industrial uses on VI, inclusive of the introduction of artificial light sources, have had little to no measurable impact on adult turtles nesting on VI and to date have not shown to have led to a long term decrease in the size of the adult marine turtle nesting population. Seabirds Several migratory bird species breed on VI, including the wedge-tailed shearwater (Puffinus pacificus), bridled terns (Sterna anaethetus) and the lesser crested tern (Sterna bengalensis). The nesting habitat on VI for these species is shown in Figure 4-2. Seabird breeding activities on VI are well documented through the implementation of a Seabird Monitoring Programme (Seabird and Shearwater Monitoring Method Statement; EA-00-RI-10058.01). Bridled and lesser crested tern populations and breeding
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activity on VI is relatively minor compared to wedge-tailed shearwaters. The wedge-tailed shearwater peak nesting season is defined as the period from 1 November to 15 April of each year (EPBC 2013/6952), however, DBCA has requested this be extended to 30 April. Artificial light potentially impacts breeding seabirds on VI in much the same way as it does marine turtles. i.e. by altering visual cues for orientation or navigation resulting in behavioural responses which can alter foraging and breeding activity. Among seabird species with a nocturnal component to their life cycle, artificial light affects the adult and fledgling differently. Adult Procellariiformes species (i.e. shearwaters, storm petrels, gadfly petrels) are vulnerable to the impacts of artificial light when returning to and leaving the nesting colony. A recent study shows artificial light disrupts adult nest attendance and thus affects weight gain in chicks (DoTEE, 2019). Much of the literature concerning the effect of lighting upon seabirds relates to the synchronised mass exodus of fledglings from their nesting sites. Emergence during darkness is believed to be a predator- avoidance strategy and artificial lighting may make the fledglings more vulnerable to predation. Artificial lights are also thought to override the sea-finding cues provided by the moon and star light at the horizon and fledglings can be attracted back to onshore lights after reaching the sea. It is possible that fledglings that survive their offshore migration cannot imprint their natal colony, preventing them from returning to nest when they mature. The consequences of exposure to artificial light on the viability of a breeding population of seabirds is unknown (DoTEE, 2019). All seabirds are sensitive to the violet – blue region of the visible spectrum (380 - 440 nm). The eyes of the Wedge-tailed Shearwaters are characterised by a high proportion of cones sensitive to shorter wavelengths, an adaptation likely due to the need to see underwater (the optimum wavelength for vision in clear blue oceanic water is between 425 and 500 nm). In all seabirds, their photopic vision (daylight adapted) is most sensitive in the long wavelength range of the visible spectrum (590 – 740 nm, orange to red) while their scotopic (dark adapted) vision is more sensitive to short wavelengths of light (380 – 485 nm, violet to blue) (DoTEE, 2019). Infrastructure on VI is currently and historically illuminated 24-hours a day. Increased light levels may cause local disruption of seabird behaviour patterns, for example wedge-tailed shearwater breeding/nesting activity or disorientation of their offspring. Gas flares also affect seabirds and anecdotal evidence suggests Wedge-tailed shearwaters maybe attracted to the light and noise of the flare (DoTEE, 2019). Despite this, migratory birds continue to breed successfully and consistently as evidenced in annual seabird monitoring. This would indicate that lighting has a negligible impact on migratory birds utilising VI for roosting and nesting activities.
9.3.2.2 Light Emissions during Installation (including Module Delivery)
VICPOP installation activities (including barge unloading and the transport of modules and ancillary facilities) are not scheduled to be undertaken outside of daylight hours and therefore will not result in artificial light emissions and/or impact on turtle nesting beaches and/or wedge-tailed shearwater rookeries.
9.3.2.3 Light Emissions during Pre-Commissioning, Function Testing and Commissioning
Pre-commissioning activities such as NDE work (e.g. radiography and hydrotesting) may be required to be undertaken at night to avoid interaction with the workforce and therefore has the potential to impact on wedge-tailed shearwaters and marine turtles if undertaken during the breeding seasons and uncontrolled. Management measures to avoid night pre-commissioning works will include the use of exclusion zones to segregate the workforce and scheduling work during designated break times. If undertaking the works outside of day-shift hours, this will occur immediately before or after the regular shift times. If lighting is required for these activities, the lighting would be task specific, localised, adequately shielded and of short duration (typically not extending over consecutive nights). Flaring from the two shielded low pressure (LP) ground flares (Harriet and ES flares) on VI does not result in detectable light overspill to the nearby turtle nesting beaches. However, process upset flaring
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from the high pressure (HP) elevated flares contributes to additional light being emitted with the potential for the elevated VI flares to disrupt breeding marine turtles and seabirds, particularly during periods of nesting and hatching. During VICPOP commissioning, high pressure flaring in the event of a process upset conditions (such as a compressor failure or plant trips etc) is not anticipated, however, as stated in Section 9.2.2.3 the ES gas plant blowdown takes approximately 15 minutes from high operating pressure to safe low levels. Where possible, the shielded ground flare is utilised.
Lighting Required for VICPOP Operations The VICPOP will result in a permanent change in lighting as new facilities will operate on a 24 hour per day basis. The provision and use of permanent artificial lighting has been assessed within an activity- specific Illumination Plan (VICP Process Facility Outdoor Illumination Plan, JB-10-RE-00044) that has been developed in accordance with EAG No. 5 and subjected to an independent review and assessment conducted by marine turtle subject matter expert Pendoley Environmental. The Illumination Plan will ensure the permanent lighting installed during the activity complies with workplace health and safety illumination levels while minimising artificial light impacts to sea turtle and shearwater breeding activities. Each of the three levels of the inlet compression modules inclusive of stair towers will be fitted with between 22 and 35 luminaires. The generator and transformer units will also be fitted with 16 to 20 luminaires respectively and five luminaires will light the bund access walkways. These luminaires are designed to prevent direct visibility of radiating elements to beaches. The VICPOP is shielded from a direct line of sight to Pipeline Beach (to the north) by the ES gas plant and the bund wall surrounding the VICPOP works area will also provide partial shielding of the facility to the turtle nesting beaches to the west (Figure 4-1). Further light spill controls shall be provided by minimising the height of each light fixture and by ensuring that the direct light (i.e. light fixture filament) of the luminaire is not visible from the turtle nesting areas (Figure 4-1). The lighting design proposed will be constructed on the basis that the closest turtle nesting zone is 100 m from the process facilities. The nesting zones at Mangrove Beach and Pipeline Beach are 130 m and 135 m respectively. Importantly, the VICPOP process facility lights will only be turned on for routine inspections. The VICPOP will not increase operational flaring requirements on VI. The VICPOP illumination requirements are relatively minor compared to existing light sources on VI (e.g. gas plant, flares, accommodation camps, etc.).
Pre-treatment Risk
Likelihood Consequence Ranking Probable Moderate In the absence of appropriate Based on current ecological knowledge on marine controls, it is probable that turtles and seabirds, additional lighting on VI could artificial lighting associated with disrupt breeding cycles of local populations in close the VICPOP installation, pre- proximity to VICPOP. Although possible that local commissioning, function testing population sizes at turtle nesting beaches and High and commissioning activities shearwater rookeries could decrease over time, could affect local marine turtle overall population viabilities on VI and surrounding and seabird populations. islands would not be threatened. Conservatively, the consequence ranking has been determined as moderate rather than minor; and this is consistent with the VI Hub Operations EP.
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VICPOP lighting management requirements are described in Section 9.3.5. Light will be managed in accordance with an established management framework as detailed in Section 6.3.4 of the VI Hub Operations EP and the VI Lighting Management Plan (VILMP) (EA-60-RI-00153, revision 9). Specific VICPOP design and operational lighting management measures have been considered and are outlined in the VICP Process Facility Outdoor Illumination Plan (JB-10-RE-00044). Lighting impacts were assessed under the EPBC Act and the associated referral lighting management commitments and assessment conditions are described in Section 9.3.5.
Measurement of Environmental Performance
Artificial light from installation and Environmental Hazard commissioning activities affecting fauna, specifically breeding turtles and seabirds. Facilities designed, installed and Performance Objective commissioned so that light emissions are ALARP. Responsible Performance Standard Measurement Criteria Person Lighting Design (Process Facilities) In accordance with the VI Lighting Management As-built plans and lighting VICPOP Plan (QE-60-RI-00153, revision 9), a project checklist confirms design Project illumination plan is developed. The VICP Process controls have been Manager Facility Outdoor Illumination Plan (JB-10-RE- implemented. 00044) ensures lighting is minimised through the following design controls: + Designing instrumentation to facilitate a ‘lights off’ philosophy. + Selection of luminaires with wavelengths with appropriate spectral qualities. + Minimising the height of each light fixture. + Preventing the primary luminary surfaces from being directly visible from turtle nesting beaches. + Minimising the number of light fittings while meeting the Illumination lux levels for emergency egress and attendance lighting. VICPOP Installation, Pre-commissioning, Function Testing and Commissioning In accordance with EPBC conditions of approval Daily vessel report confirms VICPOP (2013/6952), barge landing and unloading will not no barge landing or Project be undertaken outside of daylight hours during unloading undertaken Manager the wedge-tailed shearwater breeding season outside of daylight hours and turtle peak nesting season (1 October – 30 during the sensitive fauna April). period. In accordance with EPBC conditions of approval Site inspections and/or audits VICPOP (2013/6952), VICPOP installation activities will confirm no installation Project not be undertaken outside of daylight hours activities undertaken outside Manager during the wedge-tailed shearwater breeding of daylight hours during the season and turtle peak nesting season (1 October sensitive fauna period. – 30 April).
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Artificial light from installation and Environmental Hazard commissioning activities affecting fauna, specifically breeding turtles and seabirds. Facilities designed, installed and Performance Objective commissioned so that light emissions are ALARP. Responsible Performance Standard Measurement Criteria Person Pre-commissioning testing activities required to Audit records demonstrate VICPOP be undertaken outside of daylight hours during that an activity-specific Project the wedge-tailed shearwater breeding season illumination plan was Manager and turtle peak nesting season (1 October – 30 developed and addresses April), will be undertaken in accordance with an the requirements of the VI activity-specific illumination plan. Lighting Management Plan (EA-60-RI-00153). Monitoring In accordance with the EPBC referral Completed ‘as-built’ audit Project HSE (2013/6952), an as-built survey will be undertaken report available prior to the Advisor to assess if external light sources1 (installed as next turtle nesting season. part of VICPOP) are directly visible from the main turtle nesting beaches using suitable light monitoring equipment. In accordance with the EPBC referral Audit records demonstrate Project HSE (2013/6952), artificial light monitoring will be that artificial light monitoring Advisors undertaken every six months commencing prior to completed and reports installation and concluding one breeding season available. post commissioning of the facilities described within this BD (i.e. the 2021/22 breeding season). In accordance with the EPBC referral Post commissioning audit Project HSE (2013/6952), a post commissioning biological demonstrate that the survey Advisors survey of hatchling orientation will be conducted was completed and the to record the ‘sea finding’ success for turtle report available. hatchlings. If lighting is found to be having a statistically significant impact on turtles beyond pre-VICPOP levels, lighting mitigation measures will be re-examined and lighting changes will be made.
Post-treatment Risk
Likelihood Consequence Ranking Unlikely Minor Due to extensive management Owing to extensive lighting design considerations, controls, artificial lighting no installation activities outside of daylight hours, a associated with the VICPOP ‘lights off’ philosophy during operations and Low installation, pre-commissioning, monitoring programs and studies to detect potential function testing and impacts to marine turtles and seabirds, VICPOP commissioning activities is lighting will be of ‘minor’ consequence to these
1 Light source: Artificial lighting including light bulbs, elements or filaments.
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Likelihood Consequence Ranking ‘unlikely’ to affect the breeding species, i.e. no decrease in local population size, success or local population reduction in area of occupancy of species, loss or viability of marine turtles or disruption of habitat critical areas, or disruption to seabirds on VI. the breeding cycle is expected.
Demonstration of ALARP With the described controls, the consequence of artificial light on marine turtles and seabirds is considered to be ‘minor’. When developing the suite of controls for the management of VICPOP lighting, EAG (5) Guidelines for Protecting Marine Turtles from Light Impacts, was considered including keeping light off the beach, reducing intensity, and selecting appropriate wavelengths. Certain light levels are required to comply with safety standards and expectations. Further, additional lighting mitigation measures such as facility enclosure and shielding could result in unintended safety risk increases (e.g. fire and explosion risks). Both the financial and safety costs of implementing further controls to limit light exposure to turtle nesting beaches and wedge-tailed shearwater rookeries have been assessed and are considered disproportionately high to the small increase in environmental benefit. Hence, the proposed control measures are considered to be ALARP.
Acceptability Evaluation Based on the range of controls implemented to manage light emissions associated with VICPOP activities, potential impacts to light sensitive conservation significant fauna is considered to be environmentally acceptable. A detailed acceptability evaluation is provided below.
Is the consequence ranked as A or B? Yes – Maximum consequence from light emissions is B (Minor). Is further information required in the No – Potential impacts and risks are well consequence assessment? understood through the information available. Are risks and impacts consistent with the Yes – Activity evaluated in accordance with Santos principles of ESD? WA’s Environmental Hazard Identification and Assessment Procedure which considers principles of Ecological Sustainable Development (ESD). Are performance standards consistent with Yes – Management consistent with the intent of the industry standards, legal and regulatory Recovery Plan for Marine Turtles in Australia requirements, including protected matters? (2017) and EAG (5) Guidelines for Protecting Marine Turtles from Light Impacts. Consistent with VI Leases, and VICPOP EPBC conditions of approval (2013/6952). Are risks and impacts consistent with Yes – Aligns with Santos WA Environmental Santos WA Environmental Management Management Policy. Policy? Are risks and impacts consistent with Yes – No stakeholder concerns have been raised. stakeholder expectations? Are performance standards such that the Yes – See ALARP above. impact or risk is considered to be ALARP?
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10 Consultation
Varanus Island is a remote offshore island with land-access restrictions because it is a nature reserve and has an operating gas plant. As such, relevant stakeholders for this activity are largely restricted to Commonwealth and state government authorities responsible for management of the petroleum industry and the environment. Section 10 (Stakeholder Consultation) of the VI Hub Operations EP was reviewed in the preparation of this BD. Relevant stakeholders were considered to be DMIRS, DBCA, DWER, EPA and the Department of the Environment and Energy (DoEE). These stakeholders were consulted for the original VICP, and consultation outcomes are described in the accepted Varanus Island CEMP (JB-10-RI-002). Relevant government authorities have been, or continue to be, engaged in the preparation and assessment of regulatory environmental approvals (Section 3). DBCA were consulted on the re- instatement of the VICPOP through their review of the Part V Works Approval Application and directly through phone and email correspondence. DBCA has requested a copy of the VICP Process Facility Outdoor Illumination Plan (JB-10-RE-00044) for their records. Santos will provide the document and address any comments on the illumination plan should they be raised by DBCA. Consultation with DBCA is ongoing to ensure lease requirements (managed by DBCA) are adhered to for the VICPOP. Stakeholders are regularly updated through Santos WA’s Quarterly Consultation Updates. These updates detail Santos WA’s ongoing and upcoming activities, looking out three to six months. Information provided in this way is intended to afford stakeholders an opportunity to request additional information on specific activities or elements that may be of interest to them and voice any concerns or objections. VICPOP was listed as an ‘ongoing’ activity in the October 2019 Quarterly Consultation Update. Santos WA is not aware of any specific stakeholder concerns or objections about VICPOP and will continue to manage stakeholder consultation in accordance with the VI Hub Operations EP requirements.
11 Implementation Strategy
VICPOP activities will be implemented in accordance with Section 8 of the VI Hub Operations EP. This section identifies the specific systems, procedures and practices to be used to ensure that the environmental impacts and environmental risks of VI Hub activities, which include VICPOP, are continuously reduced to levels that are acceptable and ALARP. This implementation strategy will be used to ensure that all control measures and environmental performance objectives and standards detailed in this BD are met.
12 Reporting and Recording
If incidents do occur during the proposed activity, they will be reported to DMIRS under established recording and reporting requirements described in Section 9 of the VI Hub Operations EP. An end-of-activity environmental performance report will be submitted to DMIRS within 3 months of project completion. The report will be of sufficient detail to demonstrate whether the specific performance objectives and performance standards have been met. Emission and discharge reporting will be managed under the VI Hub Operations EP in accordance with Table 9-1.
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14 References
Astron, 2009. Varanus Island Vegetation Map Explanatory Notes. Report prepared by Astron Environmental Services, Leederville, WA. Astron Environmental Services December 2011. Varanus and Bridled Island Annual Vegetation Monitoring Report, Prepared for Apache Energy Limited. Perth, WA. Astron Environmental Services December 2019. Quadrant Environmental Monitoring Program Varanus and Airlie Islands Seabird Monitoring Annual Report 2019, Prepared for Santos WA Energy Ltd. Perth, WA. Beard, J. S. 1975. Vegetation Survey of Western Australia. Pilbara 1:1,000,000 Vegetation Series. Explanatory notes to Sheet 5, UWA Press, WA. Commonwealth of Australia. 2017. Recovery Plan for Marine Turtles in Australia 2017 – 2027.
Department of the Environment and Energy, 2019. Draft National Light Pollution Guidelines for Wildlife Including Marine Turtles, Seabirds and Migratory Shorebirds, Commonwealth of Australia 2019.
Department of Sustainability, Environment, Water, Population and Communities (SEWPaC), 2012. Marine bioregional plan for the North-west Marine Region. Prepared under the Environment Protection and Biodiversity Conservation Act 1999. Environmental Protection Authority (EPA). 2010. Environmental Assessment Guideline for Protecting Marine Turtles from Light Impacts, No 5. May 2010. Halfmoon Biosciences 2012. Seabird Impact Assessment for VI Works, Report Prepared for Apache Energy Limited. Perth, WA. Limpus, C.J. 2008. A biological review of Australian marine Turtles 2. Green turtle, Chelonia mydas (Linnaeus). The State of Queensland, Environmental Protection Agency, Brisbane, Queensland. Pacific Environment Limited. 2013. Varanus Island Compression Project – Air Quality Assessment (JB- 10-RI-014). Report prepared for Apache Energy Limited. Perth, WA. Pendoley Environmental 2019a. Varanus and Airlie Island Shearwater Monitoring Annual Report 2018/19. Report prepared for Santos Limited. Perth, WA. Pendoley Environmental 2019b. Varanus Island Turtle Monitoring: Annual Report 2018/19. Report prepared for Santos Limited. Perth, WA. Phoenix Environmental Sciences 2012. Short-Range Endemic Invertebrate Fauna Survey and Subterranean Fauna Desktop Review of the Varanus Island Fill Project. Report Prepared for Apache Energy Limited. Perth, WA. Poot, H., B.J. Ens, H. de Vries, M.A.H. Donners, M.R. Wernand, and J.M. Marquenie. 2008. Green light for nocturnally migrating birds. Ecology and Society 13(2): 47. Prince, R.I.T. and Chaloupka, M. 2011. Estimating demographic parameters for a critically endangered marine species with frequent reproductive omission: hawksbill turtles nesting at Varanus Island, Western Australia. Marine Biology 159(2): 355-363. Salmon, M., Wyneken, J., Fritz, E. and Lucas, M. (1992). Sea finding by hatchling sea turtles: role of brightness, silhouette and beach slope orientation cues. Behaviour, 122.
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Appendix 1 – VICPOP Scope and Applicability to Relevant Approvals Documents
Scope Summary of scope VICPOP Written VICPOP Bridging VI Hub Notification Document Operations EP + Rock bolting of precast foundations (already in-situ) in the VICPOP works area. + Install earthing grid cable and earth stakes in the VICPOP works area. + Install concrete foundations (cast in-situ) for ancillary facilities in the VICPOP works area. + Install precast and cast in-situ concrete foundation (C100 access platform) Preparatory works + Install below ground electrical conduit in the VICPOP works area. + Install culvert within ES gas plant. + Upgrade the access road between West Wharf and VICPOP works area. + Stockpile movement from the VICPOP works area to the West Wharf laydown (for the access road upgrade). + Install dead man anchors at West Wharf. Transport and + Delivery of the VICPOP equipment, process modules and pipe rack delivery of VICPOP module to West Wharf and transportation via SPMT to the VICPOP modules / works area. equipment + Installation of two Solar Mars 100 gas turbine driven compressors including scrubbers, air cooled heat exchangers, gas/gas exchanger and Joule-Thompson (JT) gas cooling valve (delivered to VI as Greenfields work prefabricated compression modules). (within the VICPOP + Installation of a prefabricated Centaur C40 gas turbine driven electrical works area) power generator module. + Installation of a pipe rack module for tie-in to the ES gas plant. + Installation of one prefabricated electrical switch room.
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Scope Summary of scope VICPOP Written VICPOP Bridging VI Hub Notification Document Operations EP + Installation of one prefabricated transformer compound and battery room. + Installation of plant utilities upgrades including instrument air and demineralised water. + Installation of Bund access walkways. + Pre-commissioning involves testing of all installed equipment, both mechanical and electrical and instrumentation (E&I). + Function testing to confirm operation, performance and control functions. + Final commissioning and introduction of hydrocarbons to the VICPOP process and power generation facilities. + Installation / upgrade Tie-In-Point (TIP) 002, C-100 Slugcatcher gas (Section
outlet. 3.9.15) + Installation / upgrade TIP 004, Liquids to C-101 produced water break (Section
vessel. 3.9.15) (Section + Installation / upgrade fuel gas for the VICPOP process area. 3.9.15) (Section + Installation / upgrade TIP 012, seal gas for VICPOP process area. Brownfields work 3.9.15) (within the East (Section Spar gas plant) + Installation / upgrade TIP 016, flare knock out drum. 3.9.15) (Section + Installation / upgrade TIP 020, valve change out at C-101. 3.9.15) (Section + Installation / upgrade utility tie-ins (via utility battery limit). 3.9.15) (Section + Installation / upgrade TIP-E14 fibre optic installation. 3.9.15)
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Scope Summary of scope VICPOP Written VICPOP Bridging VI Hub Notification Document Operations EP + Utilisation of VICPOP laydown area – Area allocated to perform “off (Section 3.9) plot” activities to support the above works. + Utilisation of VI logistics network (i.e. vessels and helicopters). (Section 3.9) + Utilisation of VI accommodation, amenities and recreation facilities. (Section 3.9.2) VICPOP support + Utilisation of VI storage area. (Section 3.9.5) services / utilities + Utilisation of VI roads. (Section 3.2) + Utilisation power supply. (Section 3.6.4) + VI fuel and chemical use. (Section 3.9.6) + Utilisation of concrete batching plant. (Section 3.9.1) + Ongoing operations of the VICPOP process and power generation VICPOP operation (Section 3.3) facilities.
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Appendix 2 – Santos WA Risk Matrix
Category Description and Response High Risk Reduction of risk required Medium Risk Reduction of risk required based on ALARP principal Low Risk Deemed acceptable based on standard risk controls in place
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Appendix 3 – Gap analysis between VI Hub Operations EP and proposed VICPOP hazards/activities
Event VI Hub VICPOP Hazard / Activities Environmental Impacts and Risks VICPOP Post Change to Operations addressed in the VI Hub Operations EP? Treatment the VI Hub EP Section Environmental Operations Risk EP required? Planned Activities Underwater noise 6.1 Acoustic disturbance to marine fauna from the delivery and offloading of VICPOP prefabricated modules, Yes – Underwater noise of this nature is Low No electrical power generator and ancillary facilities at West Wharf. identified in the VI Hub Operations EP. Activities associated with the VICPOP scope are not expected to cause an increase in underwater noise The activity will be managed in accordance above that already described in the VI Hub Operations EP. with the VI Hub Operations EP and no additional controls are required. Air emissions 6.2 Activities associated with the VICPOP scope which may result in additional air emission sources, include: Yes – Air emissions of this nature are To be Yes – + Point source emissions from two compressor turbine exhaust stacks and a gas turbine generator identified in the VI Hub Operations EP. assessed in a Bridging exhaust stack. The activity will be managed in accordance Bridging Document Document for exhaust + Fugitive air emissions from fuel burning equipment (e.g. mobile generators and plant). with the VI Hub Operations EP and additional controls relating to exhaust stack emissions stack + Particulate matter (dust) generated from vehicle use and transport of modules. described in a Bridging Document. emissions Activities associated with the VICPOP scope are not expected to cause a significant increase in dust above that already described in the VI Hub Operations EP. VICPOP exhaust stack emissions are not specifically addressed in the VI Hub Operations EP. Artificial light 6.3 Artificial light from VICPOP scope affecting fauna, specifically breeding turtles and seabirds, is addressed Yes – Artificial light of this nature is identified To be Yes – in the VI Hub Operations EP for the operation of VICPOP (refer to Table 6.3.4). in the VI Hub Operations EP. assessed in a Bridging Artificial light from VICPOP design, installation and commissioning scopes is not specifically addressed in The activity will be managed in accordance Bridging Document the VI Hub Operations EP. with the VI Hub Operations EP and additional Document for VICPOP controls relating to lighting design, and light installation and commissioning activities, emissions described in a Bridging Document. Disturbance of land and 6.4 The VICPOP scope is not expected to disturb land or native vegetation above that already described in the Yes – The activity will be managed in Low No native vegetation VI Hub Operations EP. The work will be undertaken within the reclaimed bund area. This area was accordance with the VI Hub Operations EP prepared as a component of the earlier VICPOP preparatory works in circa 2014 and 2019. and no additional controls are required.
Planned disturbance to 6.5 Grounding of barge vessels on the seabed during the delivery and offloading of VICPOP prefabricated Yes – The activity will be managed in Low No seabed modules and ancillary facilities. accordance with the VI Hub Operations EP Seabed disturbance resulting from the grounding of the barge vessel on the seabed will be proportional to and no additional controls are required. the hull area of each grounded barge (approximately 100 m x 30 m). Barges will be moored to onshore dead-man anchors (installed during VICPOP preparatory works). Disturbance to terrestrial 6.6 Disturbance of terrestrial fauna from VICPOP installation and commissioning activities. Yes – The activity will be managed in Low No fauna The delivery, installation and commissioning of the VICPOP prefabricated modules and ancillary facilities is accordance with the VI Hub Operations EP not expected to cause an increase to the disturbance of terrestrial fauna above that already described in and no additional controls are required. the VI Hub Operations EP. Primary risk to terrestrial fauna, being birds, will be light emissions. Disturbance to marine fauna 6.7 The delivery of VICPOP prefabricated modules and ancillary facilities via barges is not expected to cause Yes – The activity will be managed in Low No an increase in physical disturbance to marine fauna above that already described in the VI Hub Operations accordance with the VI Hub Operations EP EP. and no additional controls are required. Primary risk to marine fauna will be light emissions. Planned discharges to the 6.8 General marine vessel (barge) emissions (e.g. engine cooling water, etc.) and ballast water exchange will Yes – The activity will be managed in Low No marine environment be required at the West Wharf. Localised discharges of short duration (two barge deliveries are scheduled). accordance with the VI Hub Operations EP Such discharges are provided for in the VI Hub Operations EP. and no additional controls are required.
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Event VI Hub VICPOP Hazard / Activities Environmental Impacts and Risks VICPOP Post Change to Operations addressed in the VI Hub Operations EP? Treatment the VI Hub EP Section Environmental Operations Risk EP required? Planned water management 6.9 Rain and stormwater management within the VICPOP works area is managed through an existing open Yes – The activity will be managed in Low No on Varanus Island and closed drainage system. Potentially contaminated water is directed through an existing humeceptor accordance with the VI Hub Operations EP oily water separator prior to discharge to a sediment retention basin. and no additional controls are required. Spool hydrotesting will be undertaken using potable water free of corrosion inhibitors and oxygen scavenging chemicals and therefore will not require a controlled disposal method. On completion of spool hydrotesting, waste water will be discharged into existing storm water drainage lines. Interaction with other users of 6.10 The delivery of VICPOP prefabricated modules and ancillary facilities via barge is not expected to interfere Yes – The activity will be managed in Low No the sea with other users of the sea. Short duration activity, and standard maritime navigational practices and accordance with the VI Hub Operations EP notifications will be implemented as per the VI Hub Operations EP. and no additional controls are required. Recreational activities 6.11 Recreational activities (e.g. fishing, walking, swimming and snorkelling) undertaken by VICPOP Yes – The activity will be managed in Low No construction / contractor personnel may disturb marine and terrestrial fauna and flora. All personnel accordance with the VI Hub Operations EP working on VI will be expected to comply with the VI Hub Operations EP, which includes completing an and no additional controls are required. environmental awareness induction. Unplanned Events Accidental disturbance to the 7.1 Accidental disturbance to the seabed during the delivery of VICPOP prefabricated modules and ancillary Yes – The activity will be managed in Low No seabed facilities via barges resulting in a change, loss or damage to benthic habitats from accidental events. accordance with the VI Hub Operations EP Barges will be moored to onshore dead-man anchors (installed during VICPOP preparatory works), with and no additional controls are required. tender vessels aiding mooring operations; hence, barges are not expected to drift off location. Barges will use VI wharves being dedicated areas for marine operations. The risks associated with accidental disturbance to the seabed from VICPOP activities are not expected to be greater than that already described in the VI Hub Operations EP. Unplanned event – air 7.2 Unplanned release of air emissions during inlet compression and generator module installation and Yes – The activity will be managed in Low No emissions commissioning could occur from physical impacts to hydrocarbon processing equipment (e.g. from accordance with the VI Hub Operations EP vehicles, dropped objects), integrity breach of hydrocarbon containing equipment or pipelines, process and no additional controls are required. upsets leading to liquid carry over in the flare system and adverse weather/cyclones. The hazard of unplanned air emission releases from combustion processes or installation/commissioning activities are negligible compared to the hazard of a release from the large inventory of hydrocarbons contained within the existing VI Hub processing facilities, flowlines and pipelines. Function testing and pre-commissioning of the VICPOP process and power generation facilities prior to the introduction of hydrocarbons significantly reduces the likelihood of an unplanned release of hydrocarbons to air. This is standard industry practice. Introduction of non- 7.3 Introduction of non-indigenous flora and fauna species may occur from the additional vessels, equipment, Yes – The activity will be managed in Low No indigenous flora and fauna materials and personnel arriving at VI for VICPOP installation activities. accordance with the VI Hub Operations EP species Logistics between the mainland and VI will be managed in accordance with the existing VI Hub Operations and no additional controls are required. EP quarantine management controls, including the VI Quarantine Procedure and requirement for all personnel to complete an induction. Spillage of liquid or solid 7.4 Accidental spillage of chemicals, hydrocarbons, hydraulic fluids and other hazardous substances could Yes – The activity will be managed in Low No hazardous substances occur from VICPOP installation and commissioning activities. These risks are similar to those already accordance with the VI Hub Operations EP described in the VI Hub Operations EP. and no additional controls are required. Accidental discharge of non- 7.5 Inappropriate disposal, storage and transport of non-hazardous waste on land and at sea may result in Yes – The activity will be managed in Low No hazardous waste odour and attraction of animals (e.g. birds), ingestion and/or entanglement. These risks are similar to those accordance with the VI Hub Operations EP already described in the VI Hub Operations EP. and no additional controls are required. Accidental discharge of 7.6 The VICPOP installation and commissioning activities are not expected to cause an increased risk of Yes – The activity will be managed in Low No hazardous and process accidental discharge of hazardous wastes and process wastes above that already described in the VI Hub accordance with the VI Hub Operations EP wastes Operations EP. and no additional controls are required.
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Event VI Hub VICPOP Hazard / Activities Environmental Impacts and Risks VICPOP Post Change to Operations addressed in the VI Hub Operations EP? Treatment the VI Hub EP Section Environmental Operations Risk EP required? Surface release of diesel to 7.7 The delivery of VICPOP components by barge is not expected to cause an increased risk of a surface Yes – The activity will be managed in Low No the marine environment release of diesel to the marine environment above that already described in the VI Hub Operations EP. accordance with the VI Hub Operations EP Barges are designed to be grounded and seabed clearance surveys at the West Wharf will be completed and no additional controls are required. prior to barge arrival. Release of VI hub 7.8 N/A – Event not within VICPOP scope hydrocarbon (crude oil, condensate with gas) due to loss of well control of production wells Release of VI hub 7.9 Release of VI Hub Hydrocarbon (crude oil, condensate and gas) due to leaking or ruptured pipelines Yes – The activity will be managed in Low No hydrocarbon (crude oil, (subsea and onshore) during VICPOP installation and commissioning activities. accordance with the VI Hub Operations EP condensate with gas) due to Pipeline systems may be ruptured or damaged as a result of VICPOP activities thus releasing and no additional controls are required. leaking or ruptured pipelines hydrocarbons. Potential causes include vehicle impact, impact from dropped objects or swinging loads, (subsea and onshore) vessel impact with pipelines near VI or from potential ignition sources, e.g. electrical equipment, hot surfaces, hot work. These risks are similar to those already described in the VI Hub Operations EP. All work activities on VI will be managed in accordance with the existing permit to work system to ensure work is managed in a coordinated manner with appropriate supervision and controls in place. Function testing and pre-commissioning of the VICPOP process and power generation facilities prior to the introduction of hydrocarbons significantly reduces the likelihood of an unplanned release of hydrocarbons to air. Release of VI hub crude oil 7.10 N/A – Event not within VICPOP scope from storage or process onshore VI Release of VI hub crude oil 7.11 N/A – Event not within VICPOP scope from offtake tanker or oil export system Release of Heavy Fuel Oil 7.12 N/A – Event not within VICPOP scope (HFO) due to leaking or ruptured HFO storage tank of offtake tanker
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Appendix 4 – Varanus Island Emission Points to Air
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Existing Varanus Island Emission Points to Air
Emission Discharge Point Emission Discharge Point Point Location as shown in VI Height (m) Emission Points to Air
NOX, PM, Harriet Centaur Compressor (CM-11.301) 13 Discharge point A1 Acrolein Harriet Centaur Compressor (CM-11.301) 13 Discharge point A2 East Spar Power Generator (EG-6001) 5 Discharge point A3
NOX, PM East Spar Power Generator (EG-6002) 5 Discharge point A4 East Spar Power Generator (EG-6003) 13 Discharge point A5 Centaur Driven Produced Water Pump (G-306) 7.5 Discharge point A6 Gas Turbine NOX, PM, Taurus 60 (K-11A) Gas Turbine 11 Discharge point A7 Acrolein Taurus 60 (K-11B) Gas Turbine 11 Discharge point A8 Taurus T70 (K-12) Gas Turbine 12 Discharge point A9 East Spar - Taurus A (K-6401-A) Gas Turbine 13 Discharge point A10 East Spar - Taurus B (K-6401-B) Gas Turbine 13 Discharge point A11 NOX East Spar - Taurus C (K-6401-C) Gas Turbine 13 Discharge point A12 Mars 100 East Spar Sales Gas Compressor (K- 20 Discharge point A13 6401-D)
NOX, PM, Saturn Generator (PGI-9) 9 Discharge point A14 Acrolein Saturn Generator (PGI-10) 9 Discharge point A15 Black start Diesel Generator (EG-1) 6 Discharge point A16 NOX, PM Black start Diesel Generator (EG-2) 6 Discharge point A17 Harriet Elevated Flare (F-101) 35 Discharge point A18 NOX, PM, CO, Harriet Ground Flare (F-100) 15 Discharge point A19 Benzene, East Spar Elevated Flare (V- 6542) 33 Discharge point A20 n-hexane East Spar Ground Flare (V-6541) 8 Discharge point A21 Amine Train Vent 1 (AV1) 24 Discharge point A22 H2S Amine Train Vent 2 (AV2) 24 Discharge point A23
Proposed VICPOP Emission Points to Air Emission Discharge Point Emission Discharge Point Point Location as shown in VI Height (m) Emission Points to Air Mars 100 East Spar Inlet Gas Compressor (K- 12.8 Discharge point A24 0302)
NOX Mars 100 East Spar Inlet Gas Compressor (K- 12.8 Discharge point A25 0402) Centaur C40 (G-9001) Gas Turbine Generator 9.8 Discharge point A26
Santos Ltd | Varanus Island Compression and Power Optimisation Project – Bridging Document to the Varanus Island Hub Operations Environment Plan Page 45 of 46
Appendix 5 – Sign Attendance Sheet for VICPOP Review Activity
Santos Ltd | Varanus Island Compression and Power Optimisation Project – Bridging Document to the Varanus Island Hub Operations Environment Plan Page 46 of 46