Water Management – Emergency Discharge Plans 276
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275 16.0 Water management – Emergency discharge plans 276 16.0 Water management – Emergency discharge plans # Department Condition Description Completion date Status Pre-Dec 2012 Post-Dec 2012 Completion of upgraded emergency response plans to cover all 35 52d iv April 2014 regulated water and waste storage facilities 36 49h, 52d i IV 53B c Develop Emergency Discharge Management Plan July 2013 Commitments completed Evergreen Commitments Commitments work in progress Firm deliverables for that month 16.1 INTRODUCTION QGC’s water management facilities handle substantial water volumes of varying quality. A ‘best practice’ approach requires plans and procedures for situations where equipment or facility failure could result in a spill or emergency discharge. A specific response guide has been developed for unforeseen emergency discharges from critical elements in the water management system and related infrastructure. The focus is on risk scenarios using the likelihood or potential to cause significant impacts on MNES. This document presents the QGC Upstream Gas Field - Unforeseen Emergency Discharge Plan (UEDP) for the QCLNG project. The plan has been prepared to fulfil Commitment 36 of the Stage 2 CSG WMMP for compliance with the requirements of EPBC approval 53B c (formerly conditions 49h (I) and (II)) and 53B e (i) (III) (formerly Condition 52d (I) (IV)) of federal approval EPBC 2008/4398 to develop a Stage 3 CSG WMMP. 16.1.1 PLAN FRAMEWORK AND CONTEXT The UEDP has been designed as an overarching plan and Emergency Response Guideline (ERG) that links directly with existing QGC incident management and emergency response plans developed under QGC’s Environmental Management System (EMS) in accordance with the international standard AS/NZS ISO 14001. The plan is a specific response guide developed for handling unforeseen emergency discharges from critical elements of QGC’s water management system and related infrastructure. The plan is focused on scenarios that are ranked in accordance with or potential to cause significant or long-term impacts or harm to a Matter of National Environmental Significance (MNES) and events or situations that results in an abnormal state and require an immediate response in order to contain, minimise and/or to prevent – serious environmental harm as defined in Queensland's Environmental Protection Act 1994. 277 The primary risk scenarios specifically identified in this Plan include: • Loss of containment or discharges from CSG water storages and aggregation ponds; • Loss of containment or discharges from brine storages and aggregation ponds; • Uncontaminated discharge of CSG water, brine or treatment chemicals from water treatment facilities; and • Serious rupture or damage to CSG water or brine trunklines. This Plan complies with the relevant HSSE Management System standards and procedures as listed in the table of references (Section 16.1.2) and has been developed to complement all existing and future management plans and procedures for responding to environmental incidents including QGC’s site-based emergency management procedures, dam safety emergency response plans and individual pond operating plans for individual CSG regulated storages and water treatment plant (WTP) operations management plans. Emergency preparedness and response at QGC is not described in one document. There are several layers of emergency management at QGC and a range of standards, plans, procedures and guides prepared for the various organisational and system levels. An overview of emergency management at QGC is provided in Figure 16-1. This UEDP shall function as an Emergency Response Guide (ERG) for the purpose of QGC’s management structure and should be read and implemented in conjunction with the QGC Environmental Emergency Incident Response and Reporting Procedure (QCOPS-OPS-ENV-PCE-000012) and any relevant site-based emergency response procedure in place for a particular site or asset type. 16.1.2 REFERENCE DOCUMENTS This list of reference documents to the UEDP presented here should be read in conjunction with this Stage 3 WMMP: • Emergency Management Standard: QCQGC-BX00-HSS-STD-000011 (QGC, 2012); • Incident Management Plan: QCQGC-BX00-HSS-PLN-000002 (QGC, 2012); • Procedure for Environmental Emergency Incident Management: QCOPS-OPS-ENV-PCE-000014 (QGC, 2012); • Environmental Emergency Incident Response and Reporting Procedure: QCOPS-OPS-ENV-PCE-000012 (QGC, 2012); and • Site Emergency Response Procedure – Kenya: QCOPS-BX55-HSS-PCE-000001-4 (QGC, 2013). 278 BG Internal Incident Reporting Crisis Safety Case Environment Control and Investigation Management BG Standards are BG-ST-HSSE-AI- BG-ST-HSSE- Framework BG-ST-HSSE- BGA-HSSE-GEN- documents developed by 001 ENV-001 (Standards) EFF-001 ST-0900 BG Group Governance Committee . Compliance with BG Standards is mandatory for all BG employees and contractors . This document outlines the minimum mandatory QGC Incident and requirements for ensuring Near Miss Reporting, QGC Emergency all incidents and near Investigation and Management Standard This document outlines the misses are reported, Analysis Standard QCQGC-BX00-HSS-STD- fundamental concepts and investigated, analysed and QCQGC-BX00-HSS-STD- 000011 principles for emergency corrective and preventive 000011 management activities action implemented to undertaken at QGC . It prevent reoccurrence . also outlines the QGC Emergency Management System structure . A Safety Case is a document that ensures that suitable and sufficient Safety Case – Upstream QGC Incident This document measures are in place to Operations Management Plan (IMP) outlines QGS’s Incident prevent a major accident or QCOPS-OPS-HSS-SAC- QCQGC-BX00-HSS-PLN- Management System . environmental event and 000001 000002 It describes the to reduce the effects identification, notification, of these events should escalation and activation they occur . arrangements of the QGC Indicent Management Team (IMT) . It takes precedence over all ERPs . Emergency Response Procedure’s (ERPs) are a QGC Emergency site specific document that Response Procedure outlines the Emergency Environmental (site based) Emergency Incident Response for a specific Management Procedure area . QCOPS-OPS-ENV-PCE- 000014 Emergency Response Guide (ERG) The ERG is a specific Development against the response plan developed requirements of ISO 14001 for handling a particular (as part of QGC’s EMS) and type of emergency event to provide linkage between (i .e . gas explosion) . the BG Standards and They are contained as QGC’s emergency response appendices to the broader relating specifically to an Emergency Response environmental incident Procedure . management . Environmental Emergency Incident Response and Reporting Procedure QCOPS-OPS-ENV-PCE- 000012 Documents the requirements for responding to and investigating and environmental incident . This document should be referred to in conjunction with ERG’s . It shall be used to compliment the EMS Procedure for Environmental Emergency Incident Management . Figure 16-1 – QGC's environmental emergency management structure 279 16.1.3 EXCLUSIONS AND RELATIONSHIP WITH EXTERNAL PROJECTS The UEDP has been developed to incorporate QGC’s QCLNG upstream gas field CSG water management activities. In accordance with the Department variation to project conditions dated 2 November 2012 EPBC 2008/4398 QCLNG Gasfield, this plan does not incorporate elements relevant to treated CSG water provided to SunWater under the Glebe Weir or Chinchilla Weir Pipeline Projects. 60A: The proponent must treat all coal seam gas water as required under this approval before the coal seam gas water associated with the approved action enters the following pipelines: • The Kenya to Chinchilla Pipeline referred to the Department (EPC 2011/6000); and • The Woleebee Creek to Glebe Weir pipeline (EPBC 2011/6181). Once the CSG water has been treated as required under this approval and has entered the pipelines specified above, conditions 43-60 will no longer apply to that water. QGC is actively engaged with SunWater through relevant water service agreements for the projects and to develop and implement resource management and monitoring plans and operating protocols to ensure compliance with project conditions and sustainable beneficial use. While the Kenya to Chinchilla Weir and Woleebee Creek to Glebe Weir pipelines are not included in this plan, QGC has amended the Kenya Site Emergency Response Procedure (ERP) (QCOPS-BX55-HSS-PCE-000001-4) and QGC Incident Reporting Investigation Procedure (QCQGC-BX00-HSS-PCE-000017) to ensure notifications and response actions are in place to appropriately manage risks associated with augmentation of town water supplies for the Kenya to Chinchilla Pipeline Project, including relevant notification procedures. 16.2 ENVIRONMENTAL VALUES PROTECTION OBJECTIVES QGC has identified the following objectives for protecting environmental values in relation to CSG water management: • The extraction and treatment of CSG water is not causing adverse impacts to the surrounding environment, including site specific environmental values; • Treated water for beneficial reuse is meeting specified water quality criteria tailored for the intended reuse application and to avoid any adverse environmental impacts; • Avoid the potential for accidental spills and leaks of brine ponds and saline waste; • Avoid surface water contamination of nearby waterways; • Protect the groundwater quality in the vicinity of the WTP and storage ponds by minimising the potential for seepage of