Pilbara Ports Authority I Risk and Optimisation Project Dredging Dredge Management Plan
March 2017
Table of contents
1. Background 1 1.1 Proposed CROP Dredging Activity 1 1.2 Purpose of this DMP 3 1.3 Management Framework 3 1.4 Regulatory Framework 3 1.4.1 Commonwealth legislation, regulation and guidelines 4 1.4.2 State legislation, regulation and guidelines...... 4 1.5 Other Requirements 5 1.5.1 Health and safety ...... 5 1.5.2 Quality assurance . .... 5 1.5.3 Survey ...... 5 1.5.4 Port operations ...... 5 1.6 Stakeholder Consultation and Availability of the DMP 5 1.6.1 Availability of the DMP ...... 6 1.6.2 Ongoing review of the DMP ...... 6
2. Dredging and Spoil Disposal Activities 7 2.1 History of dredging at the Port of Port Hedland 7 2.2 Channel Risk and Optimisation Project.. 7 2.2.1 Channel Risk ...... 8 2.2.2 Channel Optimisation ...... 8 2.1 Dredging Works 11 2.2 Dredging Methods 11 2.2.1 Phase I - 2017: Trailer Suction Hopper Dredge...... II 2.2.2 Phase 2 - 2018: Cutter Suction Dredge and Trailer Suction Hopper Dredge II 2.3 Project Vessels 12 2.4 Locations for Offshore Disposal of Dredged materials 12
3. Environmental, Social and Amenity 15 3.1 Physical Environment 15 3.2 Sediments 16 3.3 Biological Environment 16 3.4 Social and Economic Uses of the Area 17
4. Impact Assessment 18 4.1 Environmental Outcomes 19 4.2 Risk to Environmental Objectives 20 4.3 Monitoring and Management Plans 21 4.3.1 Marine Megafauna including turtles .. 22 4.3.2 Marine Water Quality.. .. 25 4.3.3 Sediment Quality...... 30 4.3.4 Introduced Marine Species ..32 4.3.5 Hydrocarbon Management...... 35 4.3.6 Solid and Liquid Waste management . . 37 4.4 Overall Roles and Responsibilities 40
GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/349441 i 4.5 Audit and Review .40
5. References 41
Table index
Table 1 Previous approved and permitted dredging activities at the Port of Port Hedland 7
Table 2 Dredging areas for the CROP and approimate volume of material to be dredged 9
Table 3 Spoil grounds proposed for the placement of material dredged from the CROP dredging program at the Port of Port Hedland. (Data from SKM (2009 & 2011 a) 14
Table 4 Dredging project comparative volumes and duration : 19
Table 5 Environmental Factors and Objectives for Western Australia that may be influenced by CROP dredging (From WA EAG7 and WA EAG 8) 20
Table 6 Descriptions of the elements contained within the tables describing the' monitoring and management actions 21
Table 7 Environmental Management Processes for Marine Megafauna including Turtles 22
Table 8 Environmental Management Processes for Marine Water Quality (All areas except for Refuge Zone) 26
Table 9 Environmental Management Processes for Marine Water Quality. (Refuge Zone only) 28
Table 10 Environmental Management Processes for marine sediment quality management. 30
Table 11 Environmental Management Processes for Introduced Marine Pests 32
Table 12 Environmental Management Processes for Hydrocarbon Management. 35
Table 13 Environmental Management Processes for Waste Management. 38
Table 14 Positions and responsibilities for the CROP dredging operations at the Port of Port Hedland 40
Figure index
Figure 1 Channel Risk and Optimisation Project for the Port of Port Hedland 2
Figure 2 Location of the Spoil Grounds to be used to deposit material dredged during CROP dredging operations at the Port of Port Hedland 13
Figure 3 Monitoring areas and management trigger zones 76
ii I GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 Appendices
Appendix A - Abbreviations and Terms
Appendix B - CROP Dredging Area
Appendix C - The environment of offshore waters of Port Hedland
Appendix D - Risk Assessment Process
Appendix E Water Quality Monitoring
GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/349441 iii
1. Background
1.1 Proposed CROP Dredging Activity
Pilbara Ports Authority (PPA) proposes to undertake dredging and associated dredge spoil disposal activities in the Port of Port Hedland (Port) as part of its proposed Channel Risk and Optimisation Project (CROP).
PPA facilitates approximately $100 million of trade through the Port of Port Hedland every day, which currently requires the safe and efficient management of approximately 6,000 vessel movements in the port each year. At present large vessels carrying iron ore can only reach the deep waters of the Indian Ocean using the existing Port's 42 kilometre (km) long shipping Channel (Channel), which is unidirectional and tidally constrained.
The most common disruptions to the safe and efficient passage of vessels through this Channel result from engine slowdown or failure and steering failure. With vessels visiting the Port from all around the world, it is difficult to address issues of vessel maintenance and reliability and this cannot, in itself, be relied on to suitably manage a risk of this significance. To date, a Channel blockage has been avoided, however with the continued increase of vessel numbers through the Port, the likelihood of an incident increases. The Channel currently features two, naturally occurring, escape zones however, they are 15 km's apart, very limited in size, and too shallow to accommodate a bulk carrier afloat on all stages of the tide.
The CROP dredging program will help mitigate these risks by increasing navigation depths within the existing channel areas by targeting high spots within the Channel, constructing an Emergency Passing Lane adjacent to the existing outer Channel and constructing a deep water Refuge Zone for stricken vessels.
The total volume of material to be dredged is estimated to be approximately 1.913 million cubic
metres (Mm3) over a timeframe of approximately three years.
The extent of the proposed dredging is shown in Figure 1 and described further in Section 2.
GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/3494411 Jl" ~~ ', 'I, f, I II, PORTHEDLmDf o. ", § It, '/~.----N EWMA!N • c. , Deepening of n.,. Existing Chan-net \,
u,
" 'I' I . r--< .j t~·J ", ". " f " I 11, I I"", ,'I' ,l-=-_ - e! " fl, I, '.' . _" "-., _ .... ". .... - _ __ __ oM -- ,..--- ~- - -~~ -. r, 'u " I. '" ._, i I .. ,. ,1 , i r::::J Channej Optimisation Ol'edging Area ~..,hlBAAAPORTS ~ AUTHOR!T'I CHANNEL RISK &. _ Chsnnel Risk D Figure 1 Channel Risk and Optimisation Project for the Port of Port Hedland. 2 I GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 1.2 Purpose of this DMP A three-year permit under the Commonwealth Environment Protection (Sea Dumping) Act 1981 is required to undertake the CROP dredging program. This Dredge Management Plan (DMP) will form part of this permit application, as well as providing the framework for the CROP dredging activities including: • Overall management framework; • The areas where dredging is to occur; • Type of materials to be dredged; • Offshore disposal locations; • Legislation and regulations that apply to the CROP dredging program; • Environmental values to be protected, the risks that dredging may pose, and the mechanisms to be implemented to mediate these risks (Management Strategies); • Responsible parties; • Monitoring and reporting; and • Consultation. This DMP will also provide the framework to guide the preparation of a detailed operational dredge management plan to be developed by the appointed dredge contractor(s), or included within specific contract conditions accepted by the dredge contractor(s), prior to the commencement of the dredging activities. This DMP, in accordance with leading practice for dredging projects internationally, uses risk• informed decision making as the basis for the management framework. The process was transparent, interactive through the engagement of a broad stakeholder base and sought to draw upon the best available information. 1.3 Management Framework PPA will be the proponent for the CROP's dredging program in the Port of Port Hedland. PPA's Dredging Manager has overall responsibility for the implementation of dredging at the Port of Port Hedland and across all PPA ports within the Pilbara, including the CROP. The CROP dredging program will be conducted in accordance with conditions of the Sea Dumping Permit and the requirements of PPA as detailed in the contract between PPA and the dredging contractor(s) undertaking the CROP dredging works. The dredging contractor(s), once appointed, will be responsible for the implementation of the dredging program within the constraints of the requirements of PPA and the Sea Dumping Permit including this DMP. 1.4 Regulatory Framework The Commonwealth Department of the Environment and Energy (DotEE) is the primary Determining Authority for the assessment of any approvals under the Environment Protection (Sea Dumping) Act 1981, which may relate to the loading and any offshore disposal of sediment during the CROP dredging program at the Port of Port Hedland. The following sections provide a brief overview of key Commonwealth and State legislation pertinent to this DMP. GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/3494413 1.4.1 Commonwealth legislation, regulation and guidelines Commonwealth Sea Dumping Act In Australia, ocean disposal of dredged material within and outside of State and Territory waters is regulated by the DotEE under the Environment Protection (Sea Dumping) Act 1981 and the National Assessment Guidelines for Dredging 2009 (NAGD). The development of this legislation and guidelines has been guided by the Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter 1972 (London Convention) and the more recent 1996 Protocol to the London Convention, to which Australia is a signatory. These agreements aim to prevent pollution of the sea from the disposal of wastes or other matter, including dredged material. The NAGD contains provision for the granting of permits for dredging on the following basis: • An assessment of the applicant's capacity to meet their obligations under the Environment Protection (Sea Dumping) Act 1981 and any permit granted; • Establishment of a Technical Advisory and Consultative Committee (TACC) for long-term management; and • Development and the implementation of a satisfactory Environment Management Plan for the loading and disposal activities, which provides for sampling and analysis to support any future permit applications. Commonwealth Environment Protection and Biodiversity Conservation Act (1999) The Environmental Protection and Biodiversity Conservation Act (1999) (EPBC) establishes a process for the assessment and approval of proposed actions that are likely to have a significant impact on matters of national environmental significance or on Commonwealth land. Other Commonwealth legislation, regulation and guidelines Other applicable Commonwealth legislation and guidelines include, but are not limited to, the following Acts, Regulations (and relevant amendments): • Protection of the Seas (Prevention of Pollution from Ships) Act 1983; • Australian Ballast Water Management Requirements 2001; • Biosecurity Act (2015); • Biosecurity Regulations (2016); and • National Water Quality Management Strategy (Commonwealth Government of Australia 1992). 1.4.2 State legislation, regulation and guidelines The key Western Australian legislation, regulation and guidelines relevant to dredging at the Port of Port Hedland include: • Port Authorities Act 1999; • Navigable Waters Regulations 1958; • Shipping and Pilotage (Port and Harbour) Regulations 1966; • Western Australian Marine Act 1982; • Pollution of Waters by Oil and Noxious Substances Act 1987; • Marine and Harbours Act 1981; 4 I GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 • Environmental Protection Act 1986; • Environmental Protection Regulations 1987; • Fisheries Resource Management Act 1994 (the State Act addressing Introduced Marine Pests); • Pilbara water quality guidelines; • Western Australia Environmental Assessment Guidelines EAG 7 for Major Dredging Proposals (WA EPA, 2011); and • Western Australia Environmental Assessment Guidelines (EAG 8) for Environmental Factors and Objectives (WA EPA (2013). 1.5 Other Requirements 1.5.1 Health and safety The CROP dredging program shall be carried out in accordance with PPA health and safety requirements and a Health and Safety Management Plan shall be prepared by the dredging contractor(s) and approved by PPA prior to the commencement of dredging. 1.5.2 Quality assurance PPA, and the dredging contractor(s) undertaking the dredging program, shall have a Quality System certified by a third party to be compliant with ISO 9001, or equivalent. Quality records shall be kept for dredging and surveys, data management presentation and interpretation. 1.5.3 Survey Survey works will be the ultimate responsibility of PPA, however progress survey work may be undertaken by the dredging contractor(s) depending on the terms of the dredging contract. Surveys will be carried out in accordance with PPA's Hydrographic Survey Standards and Deliverables- requirements and with the requirements of the contract between PPA and the dredging contractor(s). 1.5.4 Port operations The CROP's dredging program will be carried out within an operating port and channel. The requirements for operating in the Port of Port Hedland are outlined in PPA's Port of Port Hedland Port Handbook, the Port Standards and Procedures and in consultation with the responsible Harbour Master. The requirements of PPA shall be adhered to whilst any vessels associated with the dredging program are within Port waters. 1.6 Stakeholder Consultation and Availability of the DMP Stakeholder consultation has taken place during the development of the CROP concepts, and in refining the ultimate design. Significant stakeholder engagement occurred during in the risk assessment phases of the project. Stakeholders consulted during this process included: • Pilbara Ports Authority; • Commonwealth Department of the Environment and Energy; • WA Office of the Environmental Protection Authority; 1 http://wwvv.pilbaraports.com.au/Pilba ra PortsAuth ority/med i a/Documents/PLAN N I N G%2 DAN0 %2 DDEVE L OPM E NT/Hydrographic-Survey-Standards-and-Deliverables.pdf GHD 1 Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/3494415 • WA Department of Transport; • WA Department of Fisheries; • Department of State Development; • Town of Port Hedland; • BHP Billiton; • Fortescue Metals Group; • Roy Hill; and • Care for Hedland. Ongoing involvement of stakeholders will be managed through a Technical Advisory and Consultative Committee (TACC), which has been in place for the Port of Port Hedland since 2006. PPA currently holds a five year Sea Dumping Permit for maintenance dredging within the Port (SD2013/2402). PPA facilitates a TACC, as part of the existing sea dumping permit, with the TACC meeting at least twice per annum. TACC members are informed on all matters relating to dredging in the Port, and have been briefed on the CROP dredging program as the concept and final design has developed. The T ACC is representative of industry, community and government at all levels and is inclusive of the stakeholders listed above. The T ACC will continue to meet at least twice per annum or more frequently as required, such as during dredging campaigns. The purpose of the TACC is to: • Keep stakeholders informed on dredging activities; • To provide continuity of direction and effort for environmental protection matters related to dredging and ocean disposal of dredged material; • Provide a forum for communication and resolution of any issues that may arise that stakeholders would like to be addressed; • Assist in establishment of long-term permitting arrangements, including review over development and implementation of: o Sampling and Analysis Plans; o Dredge Management Plans; and o Other research and monitoring programmes; • Review on-going management of dredging and ocean disposal activities in accordance with guidelines and permits; and • Make recommendations as appropriate. The main objective of the T ACC is to ensure a transparent process with respect to dredging and ocean disposal of dredged material. 1.6.1 Availability of the DMP This DMP will be made available on PPA's website (www.pilbaraports.com.au). 1.6.2 Ongoing review of the DMP PPA will undertake a review of the DMP following the results from each Phase of dredging to ensure it remains current. Any review of the DMP will include consultation with the T ACC. 6 I GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging. 61/34944 2. Dredging and Spoil Disposal Activities 2.1 History of dredging at the Port of Port Hedland PPA are responsible for maintenance dredging of the berths, channel and turning basin at the Port of Port Hedland. Maintenance dredging has been undertaken at the Port since 1977. There has also been a number of capital dredging programs undertaken over this time in support of several Port expansion projects. Table 1 summarises the dredging campaigns at the Port that have been approved by the Commonwealth under the Sea Dumping Act 1981. Table 1 Previous approved and permitted dredging activities at the Port of Port Hedland Year Type of Dredging Proponent' 1977 Maintenance PPA 150000 1981 Maintenance PPA 268,000 1985 Capital and Maintenance PPA 7,000,000 1986 Capital PPA 13,600,000 1990 Maintenance PPA 350,000 1993 Maintenance PPA 200,000 1994 Maintenance PPA 114,000 1997 Maintenance PPA 330,000 2001 Maintenance PPA 580,000 2002 Capital BHP Billiton 460,000 2004 Maintenance PPA 550,000 2006-07 Capital FMG 5,000,000 2007 Maintenance PPA 730,000 2008 Capital FMG 3,400,000 2009 Capital BHP Billiton 3,900,000 2010 Capital BHP Billiton 6,000,000 2010 Capital PPA 8,800,000# 2010 Maintenance PPA 930,000 2012 Capital PPA 5,880,000# 2012 Maintenance PPA 312,850 2012 Capital BHP Billiton 1,720,000# 2013 Maintenance PPA 680,839 2014 Maintenance PPA 344,789 2015 Maintenance PPA 473,395 2016 Maintenance PPA 272,048 * PPA includes the predecessor organisation Port Hedland Port Authority # Volumes includes approved under Permit, but not necessarily dredged 2.2 Channel Risk and Optimisation Project Whilst a large part of the CROP footprint is located within the existing Port and Channel, there are several components, which include areas of undisturbed seabed, and a section that overlies BHP Billiton's approved Outer Harbour Development footprint PPA's CROP dredging program can be broken down into two aspects; Channel Risk and Channel Optimisation and involves dredging activities in both State and Commonwealth waters. The Channel Risk aspect involves dredging in three areas, (a) Emergency Passing Lane, (b) the GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/349441 7 Refuge Zone Northwest of Beacon 15 and (c) deepening of the existing Channel from Beacon C7 to Beacon C1, whilst the Channel Optimisation aspect involves targeted dredging of identified high spots within the existing Channel and in the Inner Harbour. These areas are shown in Appendix B and summarised in Table 2. 2.2.1 Channel Risk Emergency Passing Lane The Channel Risk program involves limited dredging in an area adjacent and continuous with the existing Port's Channel between Beacon 15 and Beacon C3. This will create an Emergency Passing Lane to the west of the existing Channel, which will allow disabled vessels to remain in the Channel whilst allowing any following able and committed vessels to pass safely. The Emergency Passing Lane only requires targeted dredging of high spots adjacent to the existing channel to ensure a continuous and parallel alignment with navigable depths consistent with 'optimised depths' of the existing Channel. Refuge Zone Under existing Port protocols, any draft restricted and disabled vessel transiting the Channel from the Inner Harbour to Beacon 15 will be escorted by the Port's tugs into an existing Channel escape area located to the northwest of Beacon 15. The current escape areas are restricted in size and depth, which would limit the use of these areas for fully laden Capesize vesselsa to anchor safely without running aground. To mitigate the risk of damage to a stricken vessel and ensure the Channel can be kept clear for other vessels, a Refuge Zone 1.1 km in diameter and dredged to -18.5 m Chart Datum (CD), including over-dredging, will be created. A second Refuge Zone Northwest of Beacon C7 will be established by means of hydrographic survey and does not require any dredging. Deepening Outer Channel between Beacon C7 and C1 To deepen the existing Channel to -18.0m which will create more time for disabled slow moving vessels to reach deep water before the tide level becomes too low resulting in a grounding of that vessel. Deepening of the Channel from C7 to C1 by means of removal of selected areas currently above -18.0m CD would require the removal of approximately 214,000m3 of material from within the existing footprint. 2.2.2 Channel Optimisation Optimisation of the Channel is required to accommodate the expanding fleet profile of the vessels (both in size and numbers) frequenting the Port and to allow the export capacity of the Port to increase without resorting to major capital dredging. Dredging will be required to remove isolated high spots within sections of the existing Port's Channel and Inner Harbour areas to optimise navigable depths. At present the Channel's navigable depth is constrained by these shallow areas, or isolated 'high-spots', which will be targeted for dredging in the optimisation program. Only a small percentage of the Inner Harbour and channel area (-2.6%) needs to be 'optimised' to make the already existing deeper depths available for navigation. It has been determined that removing these high-spots will potentially achieve an average increase of 0.5 m in high water draft for draft restricted vessels and may allow an extra draft restricted vessel to sail on a tide .. 2 Capesize vessels are the largest ships carrying dry cargo. Their name derives from the fact that they are too large for the Suez or Panama Canals and as such have to move between oceans via either the Cape of Good Hope or Cape Horn. 81 GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 Table 2 Dredging areas for the CROP and approimate volume of material to be dredged. Dredging Location Dredging Objective Comment Area I • Channel Risk • Emergency West of the Channel 65 0.119 -15.7 to To create an Emergency Passing Lane to Widening of the channel by means of Passing between Beacon 15 -17.0 allow for disabled vessels to remain in the high spot removal. Of the 0.119 Mm3 to Lane and Beacon C3 Channel whilst allowing any following able be dredged from the Emergency and committed vessels to safely pass and Passing Lane, less than 0.01 Mm3falls reach the safe depths of the Indian within the proposed BHP Outer Ocean. Harbour Development design footprint. Outer Within the existing 155 0.214 -18.0 To deepen the existing Channel to -18.0m Deepening of the Channel from C7 to Channel Channel between which will create more time for disabled C 1 by means of removal of selected Beacon C7 and C 1 slow moving vessels to reach deep water areas currently above -18.0m CD. before the tide level becomes too low resulting in a grounding of that vessel. Refuge Zone Northwest of Beacon 97 1.567 -18.5 To create a safe deep water refuge Discreet area to be dredged as a 15 suitable for most stricken vessels. whole. Refuge Zone Northwest of Beacon 97 0 -18.5 To create a safe deep water refuge Refuge Zone has naturally occurring C7 suitable for most stricken vessels. depth and does therefore not require any dredging. Channel Optimisation Outer North of Beacon C9 27 0.013 -16.7 to To optimise the Channel's navigable Removal of selected areas currently Channel in Commonwealth -18 depths making already existing depths above the optimised design: waters available for navigation. GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging. 61/349441 9 Dredging Location Dredging Objective Comment Area I • Inner Inner harbour in 2 Less -14.9 To optimise the Channel's navigable High Spot removal only. Harbour State waters than • depths . . 0.001 TOTAL 346 1.913 10 I GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 2.1 Dredging Works The CROP's dredging program, to achieve the targets for both Risk and Optimisation, will generate approximately 1.913 Mm3 of dredged material, with approximately 1.567 Mm3 of that volume being generated from dredging activities associated with deepening and extending the Refuge Zone Northwest of Beacon 15 (-18.5 m CD). Of the remaining 0.345 Mm3. less than 0.01 Mm3 falls within BHP Billiton's Outer Harbour Development footprint for the creation of the Emergency Passing Lane. The small section of proposed dredging that falls within BHP Billiton's footprint runs along the eastern alignment of the approved Outer Harbour channel footprint between Beacon 15 and Beacon C3. This includes a small section of the Refuge Zone located northwest of Beacon 15. The CROP design also requires that some material below BHP Billiton's Outer Harbour Development design will also be targeted for removal to achieve the required depths consistent with those of the adjacent Channel. The remaining volume of dredged materials will be generated from dredging to remove isolated high spots within sections of the existing Channel and Inner Harbour areas to optimise navigable depths. The bulk of the dredging program will be undertaken in Commonwealth waters, except for a small area to be targeted within the Inner Harbour, which would account for < 1,000 m3 of high spot material. PPA is proposing to commence the dredging program associated with this Plan (and associated Sea Dumping Permit application) in August 2017. It is proposed that the dredging program will be undertaken in parallel and overlap the Port's annual maintenance dredging program and be split between the 2017 (Phase 1) and 2018 (Phase 2) maintenance dredging cycles where possible. This will allow PPA to limit dredging works to prescribed periods, and use dredging plant and equipment associated with the annual maintenance program where possible. Whilst it is planned to complete the CROP dredging program over a two-year cycle, allowance to extend the program into the 2019 (Phase 3) maintenance period will be sought to provide for any contingencies due to weather or equipment delays, or final capital works to achieve the required depths. 2.2 Dredging Methods A range of dredging approaches and equipment may be used during Phase 1, 2 and 3 for this Project and will include a Trailing Suction Hopper Dredge (TSHD) and a Cutter Suction Dredge (CSD). Matching the type of dredge to the specific dredging requirements and the nature of sediments will assist in optimising the utilisation of the dredging equipment and minimise environmental impacts. 2.2.1 Phase 1 - 2017: Trailer Suction Hopper Dredge. During Phase 1, sediments will be dredged from the CROP's footprint by only utilising a TSHD. This will include removing mostly unconsolidated sediments in the Refuge Zone and Emergency Passing Lane and some consolidated materials in the existing Channel around Hunt Point, where only a very small quantity is required to be removed to achieve the CROP's optimised Channel design. 2.2.2 Phase 2 - 2018: Cutter Suction Dredge and Trailer Suction Hopper Dredge A CSD in combination with a TSHD will be employed in Phase 2 to dredge the consolidated materials in the Refuge Zone, Emergency Passing Lane and Channel to achieve the CROP's design. The standard approach for Phase 2 will be to dredge this material using a CSD and GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944111 pump directly to TSHD via a pipeline connection for subsequent disposal in the proposed Spoil Grounds by the TSHD. An alternative approach is to dredge materials using a CSD directly into hopper barges alongside the CSD for subsequent disposal in the proposed Spoil Grounds. As a contingency measure for avoiding project delays due to inclement weather, sea state, TSHD availability, etc., the CSD may pre-cut the consolidated materials for subsequent removal and disposal in the Spoil Grounds by TSHD. Phase 3 - 2019: Contingency - Cutter Suction Dredge and Trailer Suction Hopper Dredge. Phase 3 is a contingency measure for a CSD and TSHD to dredge any material identified that was not removed during Phase 1 and 2 of dredging due to weather, equipment delays or final capital works to achieve the required depths. 2.3 Project Vessels Mobilisation of dredge plant and associated equipment will be carried out in accordance with the requirements of PPA through its contract with the dredging contractor(s) undertaking the dredging program, the requirements of the Sea Dumping Permit and PPA's standards, procedures and regulations for the Port of Port Hedland including PPA Introduced Marine Species Risk Assessment Procedure. 2.4 Locations for Offshore Disposal of Dredged materials All dredged material will be relocated to the existing Spoil Ground 7 and Spoil Ground 9 (Figure 2). The Spoil Ground numbers 7 and 9 refer to two areas that were selected from a potential nine sites originally investigated as part of a spoil ground site selection study for BHP Billiton's Outer Harbour Development (SKM 2011c). Both Spoil Grounds were assessed and approved for use as part of Outer Harbour Development (SKM 2011 a) but neither Spoil Ground has been used for any disposal of dredged material to date. These Spoil Ground areas are of sufficient size to accommodate the entire volume of dredged materials targeted under the CROP dredging program, without limiting the capacity of the grounds to accept material from BHP Outer Harbour development (should this proceed in the future). The location of these Spoil Grounds is shown Figure 2 with further detail provided in Table 3. 12 I GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 Spoil Ground 7 94 98 • • Poinl LAmlDO lOtUTlDO Spoil 7A 20" 11.&7 S 118"24-94,' E 20- 11.837' Ground 9 7B S 118' 28.&20' E 9C 7C 2QO 13.53(r S lIB' 28.634 E ~90 • 70 20" 13.560' S lIS' 24.954' E Spoil Ground 9 Pc*'il LATlTlDO lOtCTlDO 9A 19" 57.456' S IIB'23ZlSE 9B 19"57.445'5 118"24.713' E 9C 19" 58.848' 5 118" 24.726' E 90 19"58.860' S 118"23288' E . -- ."' .... po' • . .. •7A •7 8 Spoil Ground 7 ; 70 7C -----~ . , .. • APpnOACHES TO PORT HEDLAND -, - ;~:=f;~~;~:o\~ ~~~.:~~~~ .. -- .. Not to 00 used for navigation r:::;:;J Chanrel Opl"TO,alien OredgingArea Chanrel Risk OredgingArea IllJ CROP Rofuge Zone SpooJ Grounds Existing Port H&dland Channa I Project Areas CHANNEL RISK AND OPTIMISATION PROJECT seae: 1.170.000 (a.lA4 SIze) o 2 I; PORTS Hcrtzonlal aaJUm: GCS GOA IW4 DaLIJ: 20 17 00 I. ...1 .._, .._...., 1 .... ' .... 1 ~~...._ _ __,I ~~ fiAUTHORL.BAAAITY N DaWn: S8 '""""10. POR OF PORT HEDlAN:> Figure 2 Location of the Spoil Grounds to be used to deposit material dredged during CROP dredging operations at the Port of Port Hedland. GHD 1 Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 113 Table 3 Spoil grounds proposed for the placement of material dredged from the CROP dredging program at the Port of Port Hedland. (Data from SKM (2009 & 2011a) • Comment , .•.. . _,. , .. . I ••7 12 2,002.3 39.1 Mm3 Adjacent to the Channel and Refuge Zone. The best option for disposal of material derived from the Refuge Zone. It is estimated that up to 90% (-1.722 Mm3) of the total proposed dredged material will be placed here. The disposal site is in approximately 12 m of water and is described as bare sandy bottom depauperate in macro-benthic flora and fauna (SKM 2009 & 2011a) . 9 20 649.7 2.3 Mm3 Given the length of the Channel, the dredged material from the outer portion of the channel area and emergency passing lane is proposed to be disposed of at Spoil Ground 9. This will constitute approximate 10% (-0.191 Mm3) of the proposed dredged material. The disposal site is in approximately 20 m of water and is described as bare sandy bottom depauperate in macro-benthic flora and fauna (SKM 2009 & 2011a) . 141 GHD I Report for Pilbara Ports Authority- Channel Risk and Optimisation Project Dredging, 61/34944 3. Environmental, Social and Amenity Characterisation of the existing marine environments offshore from Port Hedland and an assessment of the potential impacts of the proposed CROP were undertaken based on existing knowledge of the area, in particular the large amount of information available as a result of the Public Environmental Review (PER) / Environmental Impact Statement (EIS) for BHP Billiton's Outer Harbour Development (BHP Billiton 2011). In addition to the above material, a marine benthic habitat assessment has been completed for the Inner Refuge Zone as part of the CROP (Advisian 2016). PPA also completed a Sampling and Analysis program in late 2016/early 2017 to sample and test sediments within the proposed CROP footprint to reconfirm data collected previously on sediment quality (Jacobs 2017). An overview of the offshore marine environment surrounding the Port of Port Hedland is provided below. For more detailed descriptions, refer to Appendix C. 3.1 Physical Environment The Port Hedland area is a limestone barrier coast with a large tidal range that has evolved into a mosaic of coastal landforms inclusive of offshore limestone ridges, protected embayments (such as the Inner Harbour), sandy substrata with mangroves, mud flats, salt flats and a number of islands and associated reefs. Depths are generally shallow, gradually increasing with distance from the shoreline to around -16 m CD at approximately 13 km seaward of the shoreline. The tides at Port Hedland are predominantly semi-diurnal and range from 1.4 m during neap tides to 5.8 m during springs, with the highest astronomical tide (HAT) being 7.6 m (PHPA 2006). The natural current direction in the local area is north westerly to south easterly. Influences on the currents and circulation in the North West Shelf include the Indonesian through-flow current, the Western Australian current, the Leeuwin current and large tidal ranges and cyclones (GHD 2008). Winds are generally moderate throughout the year, apart from sporadic cyclonic and strong storm events, leading to limited wind driven currents and a generally calm wave regime. Under cyclonic conditions, large waves, strong winds and storm surges can be created which can significantly alter current and wave energy patterns, and subsequent background water quality conditions. As an example, between December and May (wet season) the Pilbara region is subjected to sporadic, intense storms and an average of three to four cyclones occur each season (CSIRO 2008). Marine water quality in the region is heavily influenced by these seasonal patterns and incidences of extreme weather. Typically, nearshore waters are characterised by variable turbidity and high sedimentation rates, with associated highly variable light regimes and seawater temperatures. Offshore waters exhibit fewer extremes in the water quality, but still display occasional high levels of sedimentation and turbidity, low light and variable seawater temperatures (SKM 200gb; BHP Billiton 2011). In general, light, turbidity, seawater temperature and sedimentation rates are weather dependent and show a strong seasonal transition from the dry to the wet seasons. Large daily tidal ranges (>5 m), strong winds (gusts >50 km/h) and increased wave activity (such as associated with cyclonic activity) can impact background conditions resulting in increased turbidity (in the form of increase total suspended solids (TSS)) due to coastal runoff and wind/wave driven sediment resuspension. In summary, waters in the vicinity of the CROP are subject to naturally elevated levels of turbidity and a reduced light climate heavily influenced by seasonal weather patterns. GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 115 3.2 Sediments Data on the properties of the sediments in and around the CROP dredging areas and the two Spoil Grounds were obtained during the implementation of an approved Sampling and Analysis Plan (SAP) (Jacobs, 2017). Particle size distributions of the sediments in the Inner Harbour had the highest percentage of silt and clay, while the majority of the other sites had varying mixtures of mainly medium sand, coarse sand and gravel. The sediment from the sites at Spoil Ground 7 appeared to be the most consistent, mainly consisting of coarse sand. The results of this survey showed that all metals were below the respective NAGD (low) screening levels except for arsenic. Arsenic has been demonstrated to naturally occur in levels higher than the guideline level in the marine sediments of the Pilbara (DEC, 2006). This observation is borne out by the levels in excess of the guideline level recorded at both Spoil Grounds 7 and 9 during the Jacobs (2017) sampling program. These Spoil Ground survey results represent naturally occurring sediments as no dredged material has yet been disposed of at these locations. All other contaminants such as tributyltin, pesticides, herbicides and petroleum hydrocarbons were below the NAGD guidelines levels in all samples examined. All sediments are suitable for unconfined ocean disposal. 3.3 Biological Environment Benthic habitats offshore of Port Hedland comprise extensive plains of sand/silt with limited limestone pavement and ridges (SKM 2009). Many of the offshore limestone ridges run parallel to the coastline and support sparse assemblages of macroalgae, corals and sponges. Whilst the extensive plains of sand/silt are often bare of any sessile mega-epibenthic taxa (such as coral and macroalgae) these habitats do support smaller infaunal species and surface dwelling echinoderms. Macroalgae occurs offshore on both hard and soft substrata and however its abundance varies among different habitats and according to season. Seagrasses are common in the Port Hedland area but do not form dense communities or meadows. Seagrasses documented in the literature for the study area are ephemeral species such as Halophila ovalis that form patches of low to medium density (SKM 2009, WorleyParsons 2013). A review of habitat mapping studies (SKM 2009, WorleyParsons 2013) suggest that the CROP footprint (including the Spoil Grounds) is comprised mostly of bare sediment, which is largely devoid of suitable benthic primary producer habitat (BPPH). Corals, sponges and other sessile invertebrates will be sparse, and only occur in patches where there is suitable hard substrata for colonisation. A detailed BPPH survey of the Inner Refuge Zone confirmed these habitat predictions (Advisian 2016). The survey found that the Refuge Zone was mainly comprised of bare sediment (99.2 %) with small, isolated patches of soft and hard coral, sponges, macroalgae and seagrass. The results of these surveys confirm that the proposed dredge footprint does not contain any significant BPPH. Marine fauna of the area includes both listed and non-listed species. Of particular interest to the CROP are the marine megafauna, including whales, dugongs (Ougong dugon), green turtles (Chelonia mydas), Hawksbill turtles (Eretmochelys imbricata), flatback turtles (Natator depress us) and loggerhead turtles (Caretta caretta). Many of these species potentially occur in or migrate through the area, but are unlikely to be dependent upon habitat within the CROP footprint for population maintenance. Twenty-two (22) introduced marine pest species (IMPs) have been identified within the Port of Port Hedland and its surrounds (Huisman et a/. 2008; PPA 2010), 5 of which are included on the National Target List of Potential Introduced Marine Pest Species (NIMPIS, 2011) .. Strict 161 GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 adherence to quarantine and PPA's IMP management conditions will be a necessary requirement for any vessel associated with the CROP. 3.4 Social and Economic Uses of the Area The waters surrounding the Port of Port Hedland are used for both recreational and commercial fishing. Commercial fisheries in the immediate vicinity of the Port include: • Pilbara Trap and Line Managed Fishery • Pilbara Fish Trawl Managed Fishery . • Nickol Bay Prawn Managed Fishery • Recreational fishing common around islands and reefs All fisheries are considered sustainable (OoF 2016) and unlikely to be impeded by the short• term dredging operations associated with the CROP dredging program. There are no existing or proposed marine parks or reserves, which overlap the proposed CROP footprint or are expected to be impacted by the CROP's proposed dredging activities. Similarly, the footprint of the proposed CROP does not contain any World Heritage Properties, National Heritage Properties or Ramsar Wetlands of International Significance. GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 117 4. Impact Assessment The potential impacts of the CROP dredging program on environmental, social and amenity values of the area were assessed using an environment risk workshop involving the participation of a wide range of external stakeholders through a meeting of the T ACC. The issues to be considered in the risk assessment were developed with the assistance of the stakeholders and the assessment of the risks posed by CROP dredging program to these identified risks was also undertaken with the stakeholders in a workshop environment. Agreement on the mitigation measures required to address identified risks was again considered with the participation of the stakeholder group. The issues to be considered in the risk assessment were identified through the development of a conceptual model to visually describe the relationships between key values, threats and factors influencing the likelihood of the risk occurring and the magnitude of the impacts to values. Environmental receptors considered in the assessment were: • Fauna listed under the EPBC Act or State legislation; • Non-listed Fauna; • Marine mammals (including whales, dolphins and dugong); • Turtles; • Benthic Primary Producers (including seagrasses, macroalgae and mangroves); • Hard corals; • Fish and fisheries (Commercial and Recreational); • Amenity - Sensory Perception (Air, Noise, Vibration); • Indigenous Cultural Heritage; • Non-indigenous Cultural Heritage; and • Landscape & Visual. The following threats to the environmental receptors were used in the analysis. • Dredge operations; • Small vessel operations; • Destruction of benthic habitat; • Noise and light; • Sediment in water column - turbidity; • Chemicals in water column - metals; • Chemicals in water column - TBT; • Chemicals in sediment - metals; and • Chemicals in sediment - TBT. The potential linkages between dredging activities and the identified receptors are presented in a conceptual model. The conceptual model is presented as Figure 02 in Appendix D. 18 I GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 As discussed in the previous section, a great deal of information and data is available on the environment and potential environmental impacts of dredging as a result of the PERIEIS completed for BHP Billiton's Outer Harbour Development. The PERIEIS was conducted on a larger project than the CROP with the dredging component of the Outer Harbour Development considering the potential impacts of 54 Mm3 of dredged material taking 56 months to remove. A comparison of the two projects is provided in Table 4. The information provided in the EIS and the conclusions drawn are useful when assessing the potential impacts of the CROP. However, as the CROP is a considerably smaller dredging program (in both time and volume), impacts are projected to be substantially less than those predicted for the Outer Harbour Development as a whole. SKM (2009) reported on the benthic habitats present in the area for the Outer Harbour Project and found the marine habitats around Port Hedland to comprise: • 88% bare sediment; • 7% hard substrata; • 3% hard substrata covered with sediment; and • 2% not identified with confidence. Of the total area, 13% of the area was covered in biota with hard coral comprising 5.0 % of the area with macroalgae covering 4.4 % and invertebrates (ascidians, soft corals and sponges) covering 2.8% of the total area. In total 11.5% of the area was identified as Benthic Primary Producer Habitat (BPPH). SKM (2009) concluded that no benthic habitat, biota or community structures considered to be endemic, unique or of regional significance were found within the study area. They also found no dense or complex BPPH communities to be present. The main identified areas of habitat such as the coral reefs at Minilya Bank, Spoil Ground Reef, Weerdee Reef and Little Turtle Reef are located at least 10 kilometres from the main dredging works of the CROP and further from the Spoil Grounds that are proposed to be used. Table 4 Dredging project comparative volumes and duration. Project Spoil Ground Duration Spoil Ground 3 27 56 continuous Outer Harbour Spoil Ground 7 25.75 months of dredging Development Spoil Ground 9 1.25 over 5 years Total 54 Spoil Ground 7 1.721 A single 3 to 4 month dredging block CROP Spoil Ground 9 0.192 annually for 2 Total 1.913 (possibly 3) years 4.1 Environmental Outcomes In order for there to be a framework against which the environmental performance of the proposed dredging could be measured, management goals need to be established. The environmental outcomes (management goals) that were desired were drawn from the Western Australia Environmental Assessment Guidelines (EAG 8) (WA EPA 2011) and EAG 7 (WA EPA 2015) and in consideration of the values identified through the environmental risk workshop. These environmental outcomes are summarised in Table 5. GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944119 Table 5 Environmental Factors and Objectives for Western Australia that may be influenced by CROP dredging (From WA EAG7 and WA EAG 8) Factor Objective Benthic Communities and Habitat To maintain the structure, function, diversity, distribution and viability of benthic communities and habitats at local and regional scales. Coastal Processes To maintain the morphology of the subtidal, intertidal and supratidal zones and the local geophysical processes that shape them. Marine Environmental Quality To maintain the quality of water, sediment and biota so that the environmental values, both ecological and social, are protected. Air Quality To maintain air quality for the protection of the environment and human health and amenity. Amenity To ensure that impacts to amenity are reduced as low as reasonably practicable. Heritage To ensure that historical and cultural associations are not adversely affected. Human Health To ensure that human health is not adversely affected. Marine Fauna To maintain the diversity, geographic distribution and viability of fauna at the species and population levels. 4.2 Risk to Environmental Objectives Drawing upon the Outer Harbour Development PERIEIS, other published and unpublished information, and consultation with stakeholders and specialists, the environmental risk assessment was conducted to analyse the potential risks to identified environmental receptors from the CROP dredging activities. The risk assessment considered both the CROP's three• year dredging program (worst case), the annual maintenance dredging program for the Port of Port Hedland, and the contingency scenarios to identifying the risks and control actions. The environmental quality objectives identified in Table 5 were considered through evaluation of existing information and in the risk assessment process and the risk of a failure to meet the objectives was determined .. More details of the risk assessment are provided in Appendix D. The key risks identified through the risk assessment process where: • Risk of entrainment of turtles during dredging operations (medium risk); and • Risk of reduced water quality based on uncertainties around the use of CSD (medium risk) during extended works within the Refuge Zone. These have been defined as Tier 1 risks, which are those, which may require management actions in excess of the standard operational procedures. All other identified risks were considered low (Tier 2) being managed through what would be considered standard operations procedures. As such, action to prevent impacts to turtles and background water quality where considered a higher priority within the Monitoring and Management Plans, with all other areas adopting standard best practice or existing systems control, under a business-as-usual model. The actions are detailed in Sections 4.3.1 and 4.3.2. There are also a series of management actions to manage potential adverse impacts to marine environmental quality and these are detailed in Sections 4.3.3 to 4.3.6. 20 I GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 • : .:"' ~ .:-" r • '":" •• ~. _ .' 4.3 Monitoring and Management Plans The following sections details specific actions for the management of environmental issues during the CROP dredging program. Table 6 provides the framework for each monitoring and management element. Risk areas identified in the risk assessment are linked to the Environment Factors and Objectives presented in Table 6. There may also be additional management actions required by the Sea Dumping Permit (SDP) which would take precedence in the event of any conflicts between this DMP and the SDP. Table 6 Descriptions of the elements contained within the tables describing the monitoring and management actions. Element Description Objective What is intended to be achieved. Management The actions required to assist in meeting the objective. These can be Action single actions or multiple liked actions to address the Objective. Responsibility Who is responsible for implementing the actions. Timing The time period when the management actions need to be implemented. Measures The metrics for recording the outcomes. Reporting The way in which the compliance with the management actions and outcomes are reported. Target The thresholds which, if exceeded, require differed management actions (contingency) to be implemented. Contingency Actions to be undertake if the management action is not met. Using the framework presented in Table 6, seven monitoring and measurement plans (Tables 7 to 13) have been developed to guide the CROP dredging program. These include: • Marine mega fauna (including turtles), and • Marine water quality. o All areas o Refuge Zone only • Sediment quality • Introduced marine pests • Hydrocarbon management • Solid and liquid waste management GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944121 4.3.1 Marine Megafauna including turtles Entrainment of turtles was identified during the risk assessment process as being one of two medium risks posed by the CROP dredging program. Implementation of management measures as detailed in Table 7 was considered by the risk workshop to reduce the risk of entrainment of turtles to low. The risk of collision between marine megafauna and the dredge (or other associated vessels) is considered low. This issue has been defined as a Tier 1 Management Action and the environmental management processes are described in Table 7. Table 7 Environmental Management Processes for Marine Megafauna including Turtles. Risk Area Megafauna (including turtles) Factor(s) Marine Fauna Objective(s) To maintain the diversity, geographic distribution and viability of fauna at the species and population levels Task Action Responsibility Timing Management • Entrainment of turtles will be mitigated through fitting of TSHD with Actions drag heads with turtle tickler chains or similar. Dredging Contractor During dredging • Dredge pumps stopped as soon as practicable after completion of dredging to minimise intake of water whilst drag heads are off the Dredging Contractor During dredging sea floor. • Prior to the commencement of the dumping activities, the dredging contractor must ensure that a check is undertaken, using binoculars from a high observation platform, for marine speciess within the 'monitoring zone'« If any marine species are sighted in the Prior to dumping activities, 'monitoring zone', dumping activities must not commence until the Dredging Contractor during daylight hours only marine fauna is no longer observed in the monitoring zone, or the vessel is to move to another area of the disposal site to maintain a minimum distance of 300 metres between the vessel and any marine species. 3 Means all whales, dolphins, dugongs and marine turtles listed under the Environment Protection and Biodiversity Conservation Act 1999 4 Refers to the area within a 300 metre radius of the vessel GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging. 61/34944122 • Internal training of Marine Fauna Observer(s) (MFO), which provides clear direction on: 0 The area that comprises the 'monitoring zone' 0 How to identify marine fauna (i.e. whales, dolphins, dugong, turtles) that are known or likely to be encountered within the Port of Port Hedland. Prior to commencement of Dredging Contractor 0 The actions to be undertaken by the observer in the event dredging project of marine fauna being sighted within the monitoring zone. 0 The actions to be undertaken by the observer in the event of an incident resulting in injury or death of a marine species. • Internal training of selected dredge crew on the requirements, role and responsibilities of MFOs so that integration of MFOs into the At appropriate times Dredging Contractor management of the dredging operations can occur. throughout dredging project • Minimise impacts of the dredge through underwater noise through At all times throughout proper maintenance of equipment. Dredging Contractor dredging project Minimise impacts of light on fauna through the minimisation of • At all times throughout unnecessary light sources not required for safe operation of the Dredging Contractor dredging project dredqe. Measures Number of reported incidents involving marine fauna Dredging Contractor During Dredging Reporting/Evidence • A log detailing all marine fauna observations within the monitoring zone (during daylight operations only) shall be maintained. If dredging is by TSHD then the log shall include (as a minimum) the following information: date, name of MFO, time (commencement of pre-dumping observations), time (completion of pre-dumping observations), whether fauna was sighted in the monitoring zone Throughout dredging and Dredging Contractor during the pre-dumping monitoring period, type of marine species disposal activities identified (where possible), general comments on animal behaviour, description of mitigation measures undertaken (e.g. fauna sighted therefore pre-dumping observations recommenced), time (commencement of dumping) and time (completion of dumping). GHD I Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944 123 • PPA will undertake on board supervision over the Dredging Contractor's compliance with requirements. • Document and record any incidents involving the dredging or dumping activities that result in injury or death to any marine Dredging Contractor Throughout dredging and species. The date, time and nature of each incident and the disposal activities species involved, if known, must be recorded. Report all incidents involving dredging or dumping activities that • Immediately, but no later result in injury or death to any marine species, to PPA's Dredging Dredging Contractor than 12 hours from the time Manager following PPA's procedures. that the incident occurred. • Dredging Manager will notify PPA Environment Department who will formally notify DotEE of any incidents involving the dredging or Within 24 hours from the PPA Environment and dumping activities that result in injury or death to any marine time that the incident Heritage Manager species. occurred. • Provide PPA with a copy of the training package delivered to Marine Fauna Observers, and records of training attendance / Dredging Contractor Throughout project completion for each person trained. Target No injury or death to any marine megafauna. Dredging Contractor Throughout the project Contingency Completion of detailed incident analysis and implementation of any PPA Environment and ASAP corrective measures in consultation with DotEE. Heritage Manager 241 GHD 1 Report for Pilbara Ports Authority - Channel Risk and Optimisation Project Dredging, 61/34944