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. Santos Ltd | Varanus Island Compression and Power Optimisation Project – Bridging Document to the Varanus Island Hub Page 1 of 46 Operations Environment Plan 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 Santos Ltd | Varanus Island Compression and Power Optimisation Project – Bridging Document to the Varanus Page 2 of 46 Island Hub Operations Environment Plan 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 Santos Ltd | Varanus Island Compression and Power Optimisation Project – Bridging Document to the Varanus Page 3 of 46 Island Hub Operations Environment Plan 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 Santos Ltd | Varanus Island Compression and Power Optimisation Project – Bridging Document to the Varanus Page 4 of 46 Island Hub Operations Environment Plan 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] Santos Ltd | Varanus Island Compression and Power Optimisation Project – Bridging Document to the Page 5 of 46 Varanus Island Hub Operations Environment Plan 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 Santos Ltd | Varanus Island Compression and Power Optimisation Project – Bridging Document to the Page 6 of 46 Varanus Island Hub Operations Environment Plan the VI facilities and the Harriet Oil Field.