EA-60-RI-00176.01 Varanus Island Hub Operations Environment Plan Summary (State Waters) 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. Rev Rev Date Author / Editor Amendment 0 11/09/2019 Santos Issued to DMIRS A 21/8/19 CDM Smith Draft for Santos review Santos Ltd | EA-60-RI-00176.01 Page 2 of 97 Contents 1 Introduction 5 1.1 Operator 5 1.2 Compliance 6 1.3 Schedule 7 2 Activity Location 8 2.1 Operational Area 8 3 Description of Activity 12 3.1 Varanus Island 12 3.2 Airlie Island 14 3.3 Activities not included under this EP 14 4 Description of the Environment 15 4.1 Regional Setting 15 4.2 Benthic Habitats 15 4.3 Protected/Significant Areas 19 4.4 Threatened and Migratory Fauna 22 4.5 Socio-Economic Receptors 23 5 Stakeholder Consultation 27 5.1 Addressing consultation feedback 29 6 Environmental Hazards and Controls 29 6.1 Overview of process 29 6.2 ALARP and Acceptability Evaluation 31 6.3 Summary of Risks 32 7 Management Approach 46 8 Hydrocarbon Spill Response Arrangements 47 9 Contact Details 48 10 References 49 Santos Ltd | EA-60-RI-00176.01 Page 3 of 97 List of Figures Figure 2-1: Operational boundary for VI Hub and Airlie Island Operations 9 Figure 2-2: VI Hub and Airlie Islands Offshore Facilities 10 Figure 2-3: VI Hub Onshore Facilities 11 Figure 4-1: Benthic Habitats within the EMBA and Operational Area 18 Figure 4-2: Protected areas within and near the EMBA and Operational Area 21 Figure 6-1: Environmental impact and risk assessment process 29 Figure 6-2: Santos WA Risk Matrix 31 List of Tables Table 1-1: Joint Venture Participants in the VI Hub Operations 5 Table 2-1: Key Coastal or Mainland Features in Proximity to Varanus and Airlie Islands 8 Table 3-1: Activities that Support Varanus Island Operations 12 Table 4-1: Overview of Key Habitat Values Relevant to VI Hub Operations 16 Table 4-2: Marine Protected Areas Present within the Operational Area and EMBA 20 Table 4-1: Summary of Protected Species and Communities within the Operational Area and EMBA 22 Table 4-4: Socio-economic activities in the vicinity of the operational area and EMBA 24 Table 5-1: Summary of stakeholders engaged for VI Hub Operations EP 28 Table 6-1: Consequence level description 30 Table 6-2: Likelihood description 30 Table 6-3: Summary of the residual risk rankings associated with planned events 32 Table 6-4: Summary of the environmental risks for events associated with unplanned events 33 Table 6-5: Potential Impacts, Risks and Control Measures for Planned Events 34 Table 6-6: Environmental Impact Summary for Unplanned Events 39 Table 8-1: Summary of Maximum Credible Spill (MCS) Scenarios 47 Appendices Appendix A: Chemical Disclosure & Safety Data Sheets Santos Ltd | EA-60-RI-00176.01 Page 4 of 97 1 Introduction On 27 November 2018, Santos completed its acquisition of Quadrant Energy. This has the effect that Santos Limited is now the ultimate holding company of Quadrant Energy Holdings Pty Ltd and its subsidiaries. It has also resulted in most of the Quadrant group of entities changing their name. For example, Quadrant Energy Australia Limited has changed its name to Santos WA Energy Limited and Quadrant Northwest Pty Ltd has changed its name to Santos WA Northwest Pty Ltd. Each entity’s ABN has remained the same. Santos WA Energy Limited on behalf of Santos WA Northwest Pty Ltd and Santos WA Southwest Pty Limited (hereafter referred to as Santos WA or Company) will be responsible for all commitments and obligations in this EP. Santos WA operates the Varanus Island Hub (VI Hub), located on the North West Shelf of Western Australia (WA). The scope of this EP comprises all infrastructure and operational activities associated with the VI Hub within State waters, including: All infrastructure located on VI; The associated offshore platforms/monopods and subsea tie-backs; Vessel based activities; The subsea pipelines, flowlines and umbilicals (within State waters) between VI and the offshore facilities; The pipelines between VI and the mainland metering station and the pipeline from VI to the marine load-out terminal; Maintenance and environment monitoring on Airlie Island; and Monitoring and maintenance activities on Airlie Island (AI). 1.1 Operator Santos WA is the operator of the activity described within this EP. Table 1-1 lists Production Licences, the operators and JV partners. Table 1-1: Joint Venture Participants in the VI Hub Operations Production Permits/Pipeline Licences Operations (including non- Joint Venture Partners (% Share) (Associated producing) Operator in Bold licences are listed in Appendix A_3) TL/1, 5, 6, 8 & 9 Harriet (Alpha, Bravo, Charlie, Gipsy Santos WA Northwest Pty Ltd (87.7771%) and Bambra subsea), Sinbad, Harriet (Onyx) Pty Ltd (12.2229%) Access Campbell, Tanami, Rosette, Authorities Agincourt, Wonnich, Simpson, - ADW 12/91-2 Gibson / South Plato, Victoria, Double Island, Twickenham, Linda - ADW 10/92-3 PL 29 East Spar Gas Plants Trains 1 and 2 Santos WA Southwest Pty Limited (25%) (VI), Amine (CO2 Removal) Plants Santos WA East Spar Pty Limited (25%) Train 1 and 2, East Spar Ground and Santos WA Kersail Pty Ltd (5%) Elevated Flares Santos (BOL) Pty Ltd (45%) PL 12 Harriet LTS Gas Plants Trains 1, 2 Santos WA Northwest Pty Ltd (87.7771%) and 3 (VI), Liquids Separation Plant Harriet (Onyx) Pty Ltd (12.2229%) (VI), Harriet Ground and Elevated Flares, Bulk Crude and Condensate Santos Ltd | EA-60-RI-00176.01 Page 5 of 97 Production Permits/Pipeline Licences Operations (including non- Joint Venture Partners (% Share) (Associated producing) Operator in Bold licences are listed in Appendix A_3) Storage Tanks (VI), Marine Export Terminal, Produced Formation Water Treatment System including Rosette, Alkimos and Simpson depleted gas/oil reservoirs PL 30 John Brookes and East Spar Santos WA Southwest Pty Limited (25%) Pipelines which feed into East Spar Santos WA East Spar Pty Limited (25%) Gas Plant Santos WA Kersail Pty Ltd (5%) Santos (BOL) Pty Ltd (45%) TL/2 Airlie Santos WA Southwest Pty Limited Chervil (well head platform removed (66.834%) but subsea infrastructure remains) Hydra Energy (WA) Pty Ltd (23.166%) South Pepper Tanami Energy Pty Ltd (10.000%) North Herald Santos (BOL) Pty Ltd (0%) PL 14 Airlie Island Licence Area 1.2 Compliance P(SL)(E)R 2012 Requirements Regulation 11 (3) & (4) (3) Within 10 days after receiving notice that the Regulator has accepted an environment plan (whether in full, in part or subject to limitations or conditions), the titleholder must submit a summary of the accepted plan to the Regulator for public disclosure. (4) The summary: (a) must include the following material from the environment plan: (i) the location of the activity; (ii) a description of the receiving environment; (iii) a description of the activity; (iv) details of environmental impacts and risks; (v) a summary of the control measures for the activity; (vi) a summary of the arrangements for ongoing monitoring of the titleholder’s environmental performance; (vii) a summary of the response arrangements in the oil pollution emergency plan; (viii) details of consultation already undertaken, and plans for ongoing consultation; (ix) details of the titleholder’s nominated liaison person for the activity; and (b) must be to the satisfaction of the Regulator. PP(E)R 2012 Requirements Regulation 11 (7) & (8) Santos Ltd | EA-60-RI-00176.01 Page 6 of 97 (7) Within 10 days after receiving a notification that the Minister has approved an environment plan under subregulation (5)(a) the operator must submit to the Minister for public disclosure a summary of the plan. Penalty: a fine of $5,500. (8) A summary submitted under subregulation (7) must include the following: (a) the contact details of the operator of the pipeline activity or the operator’s agent; (b) the location of locations of the pipeline activity; (c) a general description of the existing environment that may be affects by the pipeline activity; (c) a summary of; (i) the details of the construction and layout of any pipeline; and (ii) the operational details of the pipeline activity and proposed timetables; and (iii) the environmental impacts and environmental risks of the pipeline activity; (iv) the implementation strategy included in the environment plan; and (v) the consultation that has been undertaken during the development of the environment plan that is to be undertaken in accordance with the implementation strategy. Santos WA has revised the associated EP in accordance with the Petroleum (Submerged Lands) (Environment) Regulations 2012 (P(SL)(E)R 2012) and Petroleum Pipelines (Environment) Regulations 2012 (PP(E)R 2012), requiring a revision of an accepted EP every 5 years. This EP has also considered the ‘Guidelines for the Preparation and Submission of an Environment Plan’ released by the DMIRS in November 2016 (DMP, 2016). The EP was submitted to the WA Department of Mines, Industry Regulations and Safety (DMIRS) for assessment on 11 September 2019. The operation of the Varanus Island Hub has been managed under the Varanus Island Hub Operations Environment Plan (EA-60-RI-186) Revision 6. The EP was accepted by DMIRS on 25 September 2014 and the VI Oil Pollution Emergency Plan (OPEP) (EA-60-RI- 186.2, Revision 6) was accepted by DMIRS on 21 July 2017. 1.3 Schedule The VI Hub operates 24 hours a day, 7 days a week, and routine activities may occur at any time during any season.