Simpson Oil Field Development, Offshore Abutilon Island, Lowendal Islands, North West Shelf Apache Northwest Pty Ltd Report and recommendations of the Environmental Protection Authority Environmental Protection Authority Perth, Western Australia Bulletin 1023 July 2001 ISBN. 0 7307 6646 2 ISSN. 1030 - 0120 Summary and recommendations Apache Northwest Pty Ltd proposes to construct two offshore mini platforms and install undersea pipelines connecting existing oil/gas wells to Apache’s existing Varanus Island Hub facility. The Simpson Development is expected to run for approximately 10 years. This report provides the Environmental Protection Authority’s (EPA’s) advice and recommendations to the Minister for Environment and Heritage on the environmental factors relevant to the proposal. Section 44 of the Environmental Protection Act 1986 requires the EPA to report to the Minister for Environment and Heritage on the environmental factors relevant to the proposal and on the conditions and procedures to which the proposal should be subject, if implemented. In addition, the EPA may make recommendations as it sees fit. Relevant environmental factors In the EPA’s opinion, the following are the environmental factors relevant to the proposal, which require detailed evaluation in the report: (a) Oil spill risk – spills from the development and pipeline bundle; and (b) Artificial light – potential impacts on hatchling turtles. Conclusion The EPA has considered the proposal by Apache Northwest Pty Ltd to construct two offshore mini platforms and undersea pipelines connecting existing oil/gas wells to Apache’s existing Varanus Island Hub facility. The EPA notes that the Lowendal and nearby islands are classified as reserves for conservation of flora and fauna and are used as breeding grounds by a number of sea turtle and sea bird species which are listed in the National List of Threatened Species under the Environment Protection and Biodiversity Conservation Act 1999 (Commonwealth). The EPA also notes that the proposed production project is to be located 400 metres from the shoreline of Abutilon Island, one of the offshore island nature reserves. Sea turtles have been recorded nesting on this island, however the number of turtles breeding on the island is small and, on a regional basis, Abutilon Island is a relatively minor turtle rookery. With respect to the potential for an oil spill from the Simpson Development the EPA notes: • the low probability of an oil spill occurring from the proposed development; • the detailed engineering and ecological risk assessment which the proponent has carried out; • the additional engineering safety features that have been designed into the project, such as minimisation of flanges and location of all process hardware onshore; • the installation of the two mini platforms and subsea pipelines will be timed to avoid the most sensitive season for turtles and sea birds; and • the proponent’s Oil Spill Contingency Plan will be upgraded to incorporate the proposed facilities. The EPA has concluded that, even in the unlikely event of an oil spill from the proposed development, it is not likely that that there would be significant long-term consequences for populations of turtles or birds, nor is it likely that there would be significant long-term impacts on marine habitats. It is therefore the EPA’s opinion that the proposal can be managed so that it is most unlikely that EPA’s environmental objective will be compromised. The EPA notes that artificial lighting on near-shore facilities has the potential to attract hatchling turtles and, in turn, facilitate predation by fish and sea birds. However, the Simpson Development mini-platforms will be unstaffed and the only lights necessary will be yellow i flashing warning lights for navigation safety. Literature and expert opinion indicate that such flashing lights are unlikely to attract hatchling turtles and therefore unlikely to affect levels of predation. The EPA’s opinion is that this factor can be managed to meet the EPA’s objective. The EPA has therefore concluded that it is unlikely that the EPA’s objectives would be compromised, provided there is satisfactory implementation by the proponent of the proponent’s commitments and the recommended conditions set out in Appendix 4 and summarised in Section 4. Recommendations The EPA submits the following recommendations to the Minister for Environment and Heritage: • That the Minister notes that the proposal being assessed is for the construction of two offshore mini platforms and installation of undersea pipelines. 2. That the Minister considers the report on the relevant environmental factors as set out in Section 3. 3. That the Minister notes that the EPA has concluded that it is unlikely that the EPA’s objectives would be compromised, provided there is satisfactory implementation by the proponent of the recommended conditions set out in Appendix 4, and summarised in Section 4, including the proponent’s commitments. 4. That the Minister imposes the conditions and procedures recommended in Appendix 4 of this report. Conditions Having considered the proponent’s commitments and information provided in this report, the EPA has developed a set of conditions which the EPA recommends be imposed if the proposal by Apache Northwest Pty Ltd to construct two offshore mini platforms, and install undersea pipelines, is approved for implementation. These conditions are presented in Appendix 4. Matters addressed in the conditions include the requirement that the proponent will fulfil the commitments in the Consolidated Commitments statement set out as an attachment to the recommended conditions in Appendix 4. ii Contents Page Summary and recommendations .....................................................i 1. Introduction and Background ................................................. 1 2. The proposal.................................................................... 1 3. Relevant environmental factors ............................................... 6 3.1 Oil spill risk - spills from the development and pipeline bundle.......................6 3.2 Artificial light - potential impacts on hatchling turtles..................................15 4. Conditions and commitments.................................................16 4.1 Proponent’s commitments.................................................................16 4.2 Recommended conditions.................................................................16 5. Other Advice...................................................................17 6. Conclusions ...................................................................18 7. Recommendations.............................................................19 Tables 1. Summary of key proposal characteristics 2 2. Oil spill risk for various scenarios 10 Figures 1. Location map of wells associated with Simpson Development 3 2. Proposed Simpson Development concept –general schematic 4 3. Simpson Development shoreline crossing and on-shore pipeline route 5 Appendices 1. List of submitters 2. References 3. Identification of relevant environmental factors 4. Recommended Environmental Conditions and Proponent’s Consolidated Commitments 5. Proponent’s response to submissions, and Simpson Oil Spill Response Trial 1. Introduction and background This report provides the advice and recommendations of the Environmental Protection Authority (EPA) to the Minister for Environment and Heritage on the environmental factors relevant to the proposal by Apache Northwest Pty Ltd to construct an offshore oil and gas development. The project is to be located 0.4 kilometres east of Abutilon Island and one kilometre south of Varanus Island in the Lowendal group of islands on the North West Shelf. Apache’s existing operations are centred on Varanus Island, the largest of the Lowendal Islands. Apache is currently operating nine offshore oil and gas installations, ranging in distance from 5–63 km away from Varanus Island. All of these installations are brought together into a central operations area referred to as the Varanus Island Hub. The proposed Simpson development will become an additional installation of the Varanus Hub operations. The proposed development is close to environmentally sensitive areas. All of the Lowendal Islands are reserves for conservation of flora and fauna and vested in the Conservation Commission. Given the high conservation significance of these islands, EPA determined that the proposal should be formally assessed at the level of Public Environmental Review (PER). Further details of the proposal are presented in Section 2 of this report. Section 3 discusses environmental factors relevant to the proposal. The Conditions and commitments to which the proposal should be subject, if the Minister determines that it may be implemented, are set out in Section 4. Section 5 provides Other Advice by the EPA, Section 6 presents the EPA’s conclusions and Section 7, the EPA’s Recommendations. Appendix 3 includes a summary of submissions. The proponent’s response to submissions is included in Appendix 5 as a matter of information only and does not form part of the EPA’s report and recommendations. Issues arising from this process and which have been taken into account by the EPA appear in the report itself. 2. The proposal The proposed Simpson Development proposal will make use of three existing wells and one that is the subject of a separate referral. The development will consist of: • the Simpson Alpha offshore mini-platform located at the Tanami-4