engineering, procurement, construction and installation of · engineering, procurement,...

Engineering, Procurement, Construction and Installation of Gas Export Pipeline (GEP)

for Ichthys Gas Field Development

Contract No. 800168

800168-AH-REP-0025

WDL197 AUDIT AND COMPLIANCE PLAN

of 35 Rev. 0

SUMMARY OF REVISION

Date Revision Description of revision Prepared Checked Dept

Approval

26 Nov 14 A Issued for IDC C Leyden S Lemmens P Johnson

1 Dec 14 0 Issued for Information C Leyden S Lemmens P Johnson



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TABLE OF CONTENTS (update as required)

1 GENERAL .................................................................................................................................................. 4

1.1 INTRODUCTION ...................................................................................................................................... 4 1.2 DEFINITIONS .......................................................................................................................................... 5 1.3 ABBREVIATIONS ..................................................................................................................................... 5 1.4 REFERENCES ........................................................................................................................................ 6

2 BACKGROUND ......................................................................................................................................... 7

2.1 LEGISLATIVE FRAMEWORK ..................................................................................................................... 8 2.1.1 WASTE MANAGEMENT AND POLLUTION CONTROL ACT ..................................................................... 8 2.1.2 WATER ACT ................................................................................................................................... 8 2.1.3 DECLARED BENEFICIAL USE - DARWIN HARBOUR REGION ............................................................... 9

3 LICENCE ACTIVITY ................................................................................................................................ 10

3.1 ACTIVITY DETAIL .................................................................................................................................. 10 3.2 LICENCE PERIOD ................................................................................................................................. 10 3.3 SITE DESCRIPTION .............................................................................................................................. 10

3.3.1 ENVIRONMENTAL VALUES ............................................................................................................. 13 3.3.2 HUMAN HEALTH ........................................................................................................................... 13

4 AUDIT SCOPE AND METHODOLOGY .................................................................................................. 14

4.1 AUDIT OBJECTIVE ................................................................................................................................ 14 4.2 AUDIT METHODOLOGY ......................................................................................................................... 14 4.3 AUDIT CRITERIA .................................................................................................................................. 14 4.4 AUDITOR ............................................................................................................................................. 14 4.5 AUDITEES ............................................................................................................................................ 14 4.6 AUDIT COMPLIANCE RATINGS ............................................................................................................... 15

5 AUDIT SCOPE AND METHODOLOGY .................................................................................................. 16

5.1 PREVIOUS AUDITS ............................................................................................................................... 16 5.2 AUDIT SUMMARY ................................................................................................................................. 16

Appendices Appendix A WDL197 Audit and Compliance Report Appendix B Waste Discharge Compliance Plan Audit Report

List of Tables

Table 1 Waste Management Hierarchy

List of Figures Figure 1 Location of Ichthys Field Figure 2 Ichthys GEP Pipelay Route in Darwin Harbour Figure 3 Declared beneficial use zone Darwin Harbour Region



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1 GENERAL

1.1 INTRODUCTION

The Ichthys gas field is located in Western Australia some 440km north of Broome and 800km southwest of Darwin in Permit area WA-285-P.

Figure 1: Location of Ichthys Field

The Ichthys Gas Field Development involves using a Central Processing Facility (CPF) and a Floating Production Storage and Offloading Facility (FPSO) located in the field with a number of satellite Drilling Centres (DC) consisting of manifold / subsea wells tied back to the CPF. The CPF will have facilities to separate the gas, condensate and water, gas dehydration (water dew point only), gas export compression and facilities for transfer of condensate / produced water to the FPSO. The FPSO facilities will include condensate stabilisation and storage in readiness for direct export to the market via shuttle tankers, mercury removal (from condensate), flash gas compression, MEG regeneration / reclamation and produced water treatment facilities.



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The development offshore will be phased over a number of years with additional DCs and facilities added to the CPF and FPSO to support reservoir depletion over time. The facilities on Blaydin Point, Darwin include gas receiving, LNG process plant (2 x 4.2Mtpa trains), product storage and export facilities. In addition to the production of LNG, other products produced will include LPGs and condensate. The field life will be approximately 40 years depending on production rates. The scope of work of this bid package consists of the Gas Export Pipeline (GEP) EPCI.

1.2 DEFINITIONS

MARPOL Annex IV : In 1973, IMO (International Maritime Organisation) adopted the

International Convention for the Prevention of Pollution from Ships, now known universally as MARPOL. Regulations for the prevention of pollution by sewage are contained in Annex IV of MARPOL. The discharge of sewage into the sea is prohibited, except when the ship has in operation an approved sewage treatment plant or when the ship is discharging comminute and disinfected sewage using an approved system at a distance of more than three nautical miles from the nearest land. Sewage which is not comminuted or disinfected has to be discharged at a distance of more than 12 nautical miles from the nearest land.

SAIPEM : Saipem Portugal Commercio Maritimo Sociedade Unipessoal

WORK : Requirements and services as described in this Scope of Work

1.3 ABBREVIATIONS

CPF Central Processing Facility DC Drilling Centre EPCI Engineering, Procurement, Construction and Installation FPSO Floating Production Storage and Offloading unit GEP Gas Export Pipeline LNG Liquefied Natural Gas LPG Liquefied Petroleum Gas MEG Monoethylene Glycol NT EPA Northern Territory Environment Protection Authority WA Western Australia WDL Waste Discharge Licence WWTP Waste Water Treatment Plant



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1.4 REFERENCES

No. Document No. Document Title

A1. - Water Act

A2. - Waste Management and Pollution Control Act

A3. WDL197 NT EPA (2014) Waste Discharge Licence.

A4. WDL197-1 NT EPA (2014) Waste Discharge Licence.

A5. MARPOL 73/78 Annex IV of MARPOL 73/78 Regulations for the Prevention of Pollution by Sewage from Ships. International Maritime Organisation (IMO).

A6. AS/NZS 5667.10:1992 Australian/New Zealand Water Quality - Sampling Australian/New Zealand Water Quality – Sampling Part 10: Guidance on sampling of waste waters

A7. - NT Gazette Notice. 2010. Declaration of Beneficial Uses and Objectives, Darwin Harbour Region. June 2010

A8. - NRETAS. 2010. Water Quality Objectives for the Darwin Harbour Region – Background Document. February 2010.

A9. - INPEX. 2009. Ichthys Gas Field Development Project. Draft Environmental Impact Statement.

A10. - Saipem application for Waste Discharge Licence - Appendix I

A11. 800168-AH-REP-0023 Surface Water Quality Report Semac-1 Waste Water Discharge

A12.

ANZECC (2000). Australian and New Zealand guidelines for fresh and marine water quality. Australian and New Zealand Environment and Conservation Council, Canberra.

A13. DR-S1-0950-EDR-P-03 Drawing: Semac-1 Sea Water Overboard and Intake/Discharges Locations



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2 BACKGROUND

Semac-1 is a semi-submersible pipelay barge that will be undertaking the shallow water pipelay campaign for the Ichthys project. The pipelay will commence in Darwin Harbour with the pipepull from the vessel onto the shore approach site then continue to lay pipe through Darwin Harbour, Northern Territory waters before laying down the pipe to the seabed into Commonwealth Waters. A dynamic positioning vessel will then retrieve the pipe and continue installation of the GEP through to the pipeline end termination point (PLET) in the Ichthys field. The Semac-1 does not have onboard holding tanks for storage of the treated wastewater. A number of options were investigated by Saipem. The transfer of treated wastewater would require installation of temporary on-deck storage tank capacity. This would require waste to be stored then transferred onto another vessel for discharge at a shore based receiving point. Daily transfers would not be practical. A minimum three (3) day holding period would be required. Aside frompractical, technical and logistical issues this option would also result in schedule delays, based on the following limitations:

Deck space on Semac-1 is limited and will not be able to support storage for holding tanks; Draft restrictions on the port (western) side of the pipelay route restricts vessel interactions from

that side of the vessel. In certain areas along the pipelay route supply vessels and cargo barges (carrying linepipe) will only be able to approach from the starboard side of Semac-1;

Other vessel movements, on the approach and departure from Semac-1, are limited during slack tide periods.

Transfer of treated wastewater to a receiving vessel would also interrupt unloading linepipe from the cargo barges adding further delays in pipelay activities, increasing costs of operations and furthermore increasing the potential of environmental impacts. The waste management hierarchy was considered for these alternatives. This is summarised in Table 1 below:

Table 1: Waste Management Hierarchy

Aspect Potential application to wastewater disposal Avoid It is not plausible to avoid the generation of sewage and wastewater waste

onboard the Semac-1, due to the length of time the vessel will be Darwin Harbour for.

Reduce It is not plausible to reduce the quantity of sewage and wastewater waste onboard the Semac-1, during the activity period whilst in Darwin Harbour.

Reuse There are no systems available to reuse sewage or wastewater onboard the vessel.

Recycle Recycling of treated wastewater is not considered practical. Recover Recovery of treated wastewater is not considered practical. Treat Treatment of sewage and greywater using a biologically activated and

disinfection treatment systems onboard the Semac-1 is a viable option. Dispose Disposal of treated wastewater effluent into Darwin Harbour is a viable

option.

The most practical and effective management of discharge forseen was to minimise the period of time that the Semac-1 is in Darwin Harbour and consequently NorthernTerritory waters for and apply for a WDL pursuant to Section 74 of the Water Act.



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On 12 June 2014 NT EPA issued Saipem (Portugal) Comércio Maritimo, Sociedade Unipessoal LDA (Saipem) with Waste Discharge Licence 197 (WDL197) for the discharge of waste water from the port and starboard waste water treatment systems present on the pipelay barge Semac-1 to Darwin Harbour from nominated discharge points.

2.1 LEGISLATIVE FRAMEWORK

All association with the discharge of trreated waste water and this licenced activity were removed from the Ichthys Project approval framework. Therefore the guiding legislative framework for the discharge of treated waste are the Northern Territory Waste Management and Pollution Control Act and the Water Act.

2.1.1 WASTE MANAGEMENT AND POLLUTION CONTROL ACT

Under section 17 of the Waste Management and Pollution Control Act an Environment Protection Objective (EPO) is a statutory instrument to establish principles on which:

environmental quality is to be maintained, enhanced, managed or protected; pollution, or environmental harm resulting from pollution, is to be assessed, prevented,

reduced, controlled, rectified or cleaned up; and effective waste management is to be implemented or evaluated.

In accordance with section 18 of the Waste Management and Pollution Control Act, a beneficial use, quality standard, criteria or objective declared under section 73 of the Water Act and in force is an environment protection objective for the purposes of the Waste Management and Pollution Control Act.

2.1.2 WATER ACT

Under section 74 of the Water Act the Controller may grant a person a WDL to carry out an action that would otherwise be an offence against this Act by virtue of Section 73 or because the action is unable to be authorised under the provisions of the Water Act. Section 73

(1) The Administrator may, by notice in the Gazette, declare, either generally or for an area specified in the notice, the beneficial uses, quality standards, criteria or objectives which apply to or in relation to any:

(a) waste or class of waste; or

(b) water or class of water.

(2) Subject to subsection (3), where a notice under subsection (1) is in force, every licence, permit or consent granted under this Act before or after the publication of the notice is, except to the extent that the licence, permit or consent otherwise provides, subject to the condition that nothing is to be done or suffered or permitted to be done under the licence, permit or consent which prejudices the beneficial use, quality, standard, criteria or objective specified in the notice in the area to which it applies.



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2.1.3 DECLARED BENEFICIAL USE - DARWIN HARBOUR REGION

Beneficial Use Declaration is a legislated process that aims to reduce the effects of water pollution in Darwin Harbour. As per the Declaration of Beneficial Uses and Objectives Darwin Harbour Region dated 29 June 2010 [Ref. A7]. (b) under section 73(1) of the Water Act, declare that, in relation to the waterways of Darwin Harbour

and Catchment described in the Schedule (the Darwin Harbour Region), the beneficial uses which apply:

(i) to all saline waters south of an imaginary line drawn from Charles Point to Gunn Point and

bounded by the upper limit of the high water mark of tidal waterways, including all named and unnamed inlets and creeks; are

(A) aquaculture; and

(B) environment; and

(C) cultural; and

(ii) to all natural waterways, including all names and unnamed springs, creeks, rivers, lakes,

lagoons, swamps or marshes, are:

(A) aquaculture; and

(B) environment; and

(C) cultural; and

(D) rural stock and domestic; and

(c) under section 73(1) of the Act, declare the objectives which apply in relation to the Darwin

Harbour Region are:

(i) the water quality objectives specified in Tables 8 and 9 in the document entitled Water Quality Objectives for the Darwin Harbour Region – Background Document; and

(ii) in particular water quality objectives relevant to a beneficial use applicable udner

paragraph (b) are not specified in one of those Tables – the relevant guidelines specified in Chapters 3, 4 and 5 of the document entitled Australian and New Zealand Guidelines for Fresh and Marine Water Qaulity (ANZECC 2000).

Under section 93 of the Water Act the Controller has the power to amend or modify the terms and conditions of a licence:

(1) Subject to subsections (3) and (4), the Controller may, during the currency of a licence, by notice served on the holder of the licence, amend or modify its terms and conditions in such manner as is specified in the notice.



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3 LICENCE ACTIVITY

3.1 ACTIVITY DETAIL

WDL197 was issued for the discharge of waste water from the port waste water treatment system and the starboard waste water treatment system on the pipelay barge Semac-1 to Darwin Harbour from the following authorised discharge points. Discharge Point

Description Location

1 Semac-1 Waste Water Treatment Plant – Starboard side

Starboard S3 Column Inboard Pontoon

2 Semac-1 Waste Water Treatment Plant – Port side

Port S3 Column Inboard Pontoon

1 As shown in EMC drawing No DR-S1-0950-EDR-P-03, revision 0, Semac 1 Semi-submersible Pipelay Barge, Sea Water Overboard and Intake/Discharges Locations (Appendix A). WDL Variation 1 was amended on 12 September 2014. The licenced activity in WDL197-1 was amended to:

Discharge of waste water from the port waste water treatment system and the starboard waste water treatment system on the pipelay barge Semac-1 to Darwin Harbour and Northern Territory waters from the nominated discharge points.

The licence to which this audit and compliance report relates is to be referred hereon as WDL197. This covers requirements of both licences, unless it is specifically required to be referenced.

3.2 LICENCE PERIOD

WDL197 was issued to commence on 12 June 2014 and expire on 30 September 2014. On 19 August 2014 Semac-1 taversed the Darwin Harbour Region limits. Notice of licence surrender was given to the NT EPA on 25 August 2014. Subsequently WDL197 was amended under section 93 (1) of the Water Act to cover the discharge of effluent from the on-board waste water treatment systems into Northern Territory waters. The surrender notice was rescinded and WDL197-1 issued on 12 September 2014. The licence expiry date remained as 30 September 2014. Semac-1 exited Northern Territory waters at 05:00am CST Wednesday 1 October 2014. Due to the timing of the vessel coinciding with the end of licence period there was no need to progress the renewal application as had previously been submitted to NT EPA to cover Semac-1 pipelay activity continueing in Northern Territory territorial waters into October 2014.

3.3 SITE DESCRIPTION

The site for this licence activity is for the sewage and greywater treatment system on board the pipelay barge Semac-1.

Semac-1 has two identical Holland Marine Services MSD-II sewage treatment units onboard that operate independently and concurrently. One treatment unit is located on the port side and the other treatment unit on the starboard side of the barge.



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Each treatment unit has a dedicated below water discharge point located each at the port and starboard side. The treatment system maintains current MARPOL (International Convention for the Prevention of Pollution from Ships) certification, MEPC.2 (VI) Annex VI. The discharge of treated wastewater is along the linear pipelay route in Darwin Harbour as indicated in the below reference points and [Figure 2: Ichthys GEP Pipelay Route in Darwin Harbour] below. As the proposed discharge site/area is linear, there is no site boundary.

Point 1: Semac 1 Shore Pull Location E 701 619.79 N 8 613 665.98 Point 2: Start of cable crossings E 694 448.16 N 8 623 147.01 Point 3: Darwin Harbour Limit E 680 439.11 N 8 636 057.91

Figure 2 : Ichthys GEP Pipelay Route in Darwin Harbour

The declared beneficial use zone for the Darwin Harbour region covers saline waters south of an imaginery line drawn from Charles Point to Gunn Point and bounded by the upper limit of the high water mark of tidal waterways as identified in [Figure 3. Declared beneficial use zone Darwin Harbour Region]. The declared beneficial uses also covers natural waterways including springs, creeks, rivers, lagoons, swamps or marches which are not applicable to activity within this licence. Darwin Harbour is not a closed system and experiences tides and flushing to the ocean. Discharge



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waste is expected to flush to the ocean within <35 days. Darwin Harbour experiences maximum tidal level variations of up to 8 m. Mean spring tide variations are around 6 m and mean neap tide variations around 3 m. The tides are semi-diurnal with two high tides and two low tides per day. The Water Quality Objectives for the Darwin Harbour Region guidelines [Ref. A8] classify the Darwin Harbour region as mid to outer estuary per ANZECC and Water Quality Protection Plan (WQPP) water types. The mid estuary area comprises a majority of the length of the estuary from below the upper estuary to near the mouth. It excludes smaller well flushed reaches at the mouth which typically has marine water quality. Outer estuary areas encompass coastal waters with some broader marine or ocean exchange, including shallower coastal waters or embayments. It also includes downstream reaches of estuaries. Water quality in Darwin Harbour is described as generally high, although naturally turbid [Ref. A9]. Water quality parameters vary greatly with the tide (spring versus neap), location of sampling point (inner versus outer harbour) and with the season (wet season versus dry season).

Green shaded area represents Declared Beneficial Use Zone of Darwin Harbour

Figure 3 : Declared beneficial use zone Darwin Harbour Region



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3.3.1 ENVIRONMENTAL VALUES

The Darwin Harbour shoreline is characterised by extensive mangroves and intertidal mud flats. Mangroves form a valuable part of the marine ecosystem by producing large amounts of organic matter and nutrients utilised by fauna such as crustaceans and fish. Approximately 80% of the Darwin Harbour region’s seafloor is estimated to be covered with soft surfaces consisting of mud and fine sand [Ref. A9]. Hard coral and filter-feeder communities occur in Darwin Harbour where the substrate is rocky in the lower intertidal and shallow subtidal zones and where hydrodynamic conditions permit. Filter-feeder communities primarily comprise sponges, gorgonians (sea fans and sea whips) and other soft corals [Ref. A9]. The Channel Island coral community has a high percentage cover of coral and high diversity of hard corals [Ref. A9], and similar to the coral cover at Weed Reef. Significant seagrass beds are not known to occur within Darwin Harbour. Over the broad areas of sand-veneered pavement at Weed Reef, a very sparse, patchy coverage of a seagrass (Halophila sp.) was recorded in baseline surveys for the Ichthys Gas Project. Sparse Halodule uninervis and Halophila decipiens were also recorded at Wickham Point [Ref. A9]. Seagrass was not recorded in targeted habitat surveys at the reef flat at Channel Island [Ref. A9]. A number of marine megafauna species identified as Matters of National Environmental Significance (MNES) exist in Darwin Harbour, including dolphins, turtles, dugongs and saltwater crocodiles. It should be noted that some species, such as blue whales, rarely venture into shallow water sections of the Harbour.

3.3.2 HUMAN HEALTH

Faecal coliforms may pose a human health risk if discharged in sufficiently high concentrations combined with human exposure. This was assessed as an insignificant impact for Semac-1 activity due to the mixing and dilution of discharged water into receiving waters effecting in immediate dissolution reducing any potential of localised effects.



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4 AUDIT SCOPE AND METHODOLOGY

4.1 AUDIT OBJECTIVE

The objective of this audit is ensure compliance with conditional requirements of WDL197 and WDP197-1, hereon refered to as WDL197.

4.2 AUDIT METHODOLOGY

This was a combined audit covering processes, records and systems for activity related to WDL197. The process element of this audit examined practices to confirm compliance with WDL197 requirements to ensure conditional requirements were being met. The audit also included observation of relevant records to verify that these records meet legal, regulatory or contractual requirements in order to provide evidence that processes are being performed in accordance with licence requirements. A system based audit focused on specific areas of the management system to confirm compliance with the specific requirements of the licence. This audit was largely evidence based with interviews with relevant project personnel being conducted as required.

4.3 AUDIT CRITERIA

The criteria for this audit includes:

WDL197 WDL197-1

4.4 AUDITOR

This audit was conducted by Carolyne Leyden. Carolyne has lead auditor qualification as accredited by SAI Global and has extensive experience in conduting and leading audits. This audit was conducted in compliance with the Code of Conduct for RABQSA certified persons.

4.5 AUDITEES

The auditees for this audit were all Saipem personnel.

James Pederson Environmental Advisor Marc Chatt Environmental Advisor Keith Miller Chief Engineer Semac-1 Marco Cimmino Chief Engineer Semac-1



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4.6 AUDIT COMPLIANCE RATINGS

The following compliance ratings were used in this audit:

C Assigned where there was full compliance with the element being audited.

OBS Assigned in the event of an audit evidence that could entail the partial non-fulfillment of a requirement. OBS has to be addressed through a recommended action by the auditee in consultation with the auditor in the close out meeting.

This will be noted as an area of concern in the audit summary below.

NC Assigned in cases of:

- Total or partial non-fulfillment of a requirements (e.g. procedure, contractual, statutory or a Standard requirement such as ISO 9001:2008) that could be generated a situation in which the related process is out of control.

- Not effective management on an Observation issued during previous audits on the same process.

This will be noted as a system deficiency in the audit summary below.

OFI Opportunities for improvement for the auditee.

Due to this audit being undertaken upon completion of the licensed period it is not applicable in this audit.



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5 AUDIT SCOPE AND METHODOLOGY

5.1 PREVIOUS AUDITS

An audit was conducted on 12 August 2014 on the Compliance Plan [Ref. A10]. The audit presented one finding in the training and communication section:

Saipem were unable to demonstrate that detail on the treatment system and operating conditions had been included in the vessel induction. Due to the timing of this being post mobilisation of crew it wouldn’t present any purpose in adding this detail to the vessel induction in retrospect. Saipem managed this by including information on the WWTP in pre-start/toolbox meetings. No other audits were undertaken on the WDL during the activity period.

5.2 AUDIT SUMMARY

Audit findings were assessed on the audit and compliance report template as provided by the NT EPA as Appendix C of WDL197. This audit was conducted as a requirement for WDL197 Condition 32. The audit identified that Saipem had implement and complied with the conditional requirements of WDL197. Furthermore the licencee ensured all conditional requirements of the licence were extended whilst the vessel moved from Darwin Harbour into Northern Territory territorial waters. System Deficiencies

There was one non-conformance identified in this audit. The limit exceedance was identified with the return of the first sample results and reported to NT EPA in compliance with requirements of WDL197 Condition 26. Upon review of this notification NT EPA upgraded the exceedance to a non-conformance and measures to manage the ongoing reporting of sample results were implemented. Condition 21 required that the Licensee shall ensure that all water samples are submitted to a laboratory with current NATA accreditation for the analysis specified, and analysed in accordance with the current “Standard Methods for Examination of Water and Wastewater, APHA-AWWA-WEF”. Areas of Concern

One observation was identified in this audit with condition 6. It was noted that not all correspondence included the [email protected] email address.



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This deficiency presented with emails sent directly to an NT EPA officer post the exceedance event notification where curative measures were initiated for the ongoing provision of sample monitoring reports and technical oversights where the requirements of Condition 6 were overlooked. The second observation was from Condition 21. This called for laboratories be NATA accredited and samples analysed in accordance with the current “Standard Methods for Examination of Water and Wastewater, APHA-AWWA-WEF”. All three laboratories were NATA accredited. Two of these were verified as analysing samples to the required APHA standard. The third laboratory conducted the water microbiology analysis using AS4276.21 AND ATSM D 6503-99 for ecoli and enterococci analysis respectively. The Department of Primary Industries Water Microbiology laboratory is accredited to these standards. To change the testing method would breach their lab procedures and consequently NATA accreditation. This is the only laboratory in Darwin who conduct water microbiology analysis. To source another laboratory who could perform the analysis under the required criteria would require interstate transfers jeopardising the 12 hour holding time and preservation of samples also challenging requirements of AS/NZS 5667. The licencee took all reasonable measures to ensure conditional requirements were achieved but had to make a decision on reducing risk to as low as reasonable practicable for this element of this condition. More detail is provided in the audit and compliance report in Appendix A.

Engineering, Procurement, Construction and Installation of Gas Export Pipeline (GEP) for Ichthys Gas Field Development

Contract No. 800168

Appendix A Audit and Compliance Report

800168-AH-REP-0025

WDL197 AUDIT AND COMPLIANCE REPORT

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AUDIT AND COMPLIANCE REPORT

WASTE DISCHARGE LICENCE

Page 1 of 11

LICENCE NO. WDL197-1

REPORTING PERIOD 12 June 2014 - 30 September 2014

Licence Condition How Evidence When Status

ADMINISTRATIVE

1 The Licensee must notify the NT EPA within 24 hours if

there are changes to the details of the 24-hour emergency

contact as provided on page one of this Licence.

Email to [email protected]

if there are any changes to the

emergency contact.

No changes were made to the licencee emergency contact during the

licence period.

Within 24 hours of

change

C

2 The Licensee must notify the NT EPA within 14 days if there

are changes to the Licensee details shown on page one of

this Licence.


if there are any changes to the

licensee.

No changes were made to the licencee emergency contact during the

licence period.

Within 14 days of

change

C

3 The Licensee must notify the NT EPA within 14 days after

ceasing to conduct the activity to which this Licence relates.

Complete licence surrender

form and email to

[email protected] if there

are any changes to the licensee.

The licence surrender notice was evidenced at audit as being submitted to

NT EPA on 25 August 2014, five (5) days post the Semac-1 crossing the

Darwin Harbour limit on (19 August 2014). This surrender notice was submitted for WDL197 post crossing the Darwin

Harbour limits, to which the licensed activity area was originally for.

Consequently the licence was re-issued with WDL197-1 to extend

coverage of activity within territory waters. Variation 1 of this licence had an expiry date of 30 September which

coincided with the vessel crossing the Northern Territory Water boundary.

Per the duration of the licence (page 4)

“This licence will remain in force until its expiry date, or until it is

surrendered by the Licensee, or until it is suspended or revoked by

the Controller.”

Within 14 days of

activity ceasing or

expiry

C

4 The Licensee must notify the NT EPA prior to making any

operational change that will cause, or is likely to cause, an

increase in the potential for environmental harm,

environmental nuisance, material environmental harm or

serious environmental harm.


if there are any operational

changes that impact or cause

environmental harm.

There was no change to operational activity during either of the licence

periods.

As required during

licence activity

C

5 The Licensee must cause a copy of this Licence to be

available at all times on board the pipelay barge called

Semac-1.

Send a copy to Semac-1 Vessel

Master for inclusion in onboard

approvals folder.

Email from 18 June 2014 evidenced instructing the Semac-1 Captain to

maintain a copy of the licence be available at all times onboard the Semac-

1.

Photo evidence from the vessel verified that WDL197 was available on the

Post final WDL being

received.

C

mailto:[email protected]


http://www.ntepa.nt.gov.au/search?queries_all_query=SURRENDER&x=0&y=0

http://www.ntepa.nt.gov.au/search?queries_all_query=SURRENDER&x=0&y=0



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bridge.

An email from 15 September 2014, distributing the amendment WDL was

also evidenced as being shared with relevant project personnel.

A hard copy file containing all project approvals were provided to the

Vessel Master upon commencement of Project. These were verified as

being retained in the vessel bridge.

6 Where this Licence requires the provision of any notice,

document or other correspondence to the NT EPA, the

relevant contact is:

Pollution Control, NT EPA.

Physical Address: Level 2 Darwin Plaza, 41 Smith

Street Mall, Darwin NT 0800.

Postal Address: GPO Box 3675, Darwin NT 0801.

Email: [email protected].

Noted A number of correspondence relating to WDL197 was evidenced as being

sent to the nominated [email protected] email.

8 Jul 14 Exceedance event notification

15 Oct 14 Non-Conformance Report NCO002

A number of emails relating to the ongoing reporting requirements adopted

post the limit exceedance event resulted in emails being directed to other

emails at the NT EPA’s request.

To ensure item 6 was adequately followed the [email protected] email

address should have been included in cc on all emails to the NT EPA.

As required OBS

c All notices, documents or other correspondence required to

be provided pursuant to this Licence must be provided in

electronic form unless otherwise specified as a condition of

this Licence

Noted A sample selection of correspondence was evidenced as being provided to

NT EPA electronically.

As required C

OPERATIONAL

8 The Licensee must, without limiting any other condition of

this Licence in conducting the Activity, do all things

reasonable and practicable to ensure the Activity does not

adversely affect the Declared Beneficial Uses and

Objectives as declared from time to time, including those

applying to:

8.1 Darwin Harbour Region.

Ensure all necessary project

personnel are aware of the

requirements of the licence.

WDL197 was circulated to all relevant project personnel as evidenced in

the email from P Brace from 18 June 2014.

Licence duration C




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9 The Licensee must maintain a log of each complaint, made

in relation to the Activity. The log must include details of the

following:

9.1 the date and time of the complaint;

9.2 the contact details of the complainant if known, or

where no details are provided, a note to that effect;

9.3 the nature of the complaint;

9.4 the nature of events giving rise to the complaint;

9.5 prevailing weather conditions at the time of the

complaint;

9.6 the action taken in relation to the complaint, including

any follow-up contact with the complainant; and

9.7 if no action was taken, why no action was taken.

Develop complaint log book

- run in conjunction with project

complaints as received via the

Dredging & GEP community

feedback line (1800 705 010)

Evidenced the GEP Community Complaint Log file. No complaints were

received specific to discharges from Semac-1 in Darwin Harbour or

Territory Waters during the activity period (June – September 2014). Furthermore the INPEX 1800 complaint log from June through to

September 2014 was evidence and it verified that no queries were

received from the public in relation the vessel discharge in Darwin Harbour

during this period.

1. Establish register

prior to works

commencing.

2. Add complaints as

they arise.

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10 The Licensee must implement the Compliance Plan provided as Attachment I to the Application for Waste

Discharge Licence, dated 10 March 2010, reviewed 5 June

2014.

Distribute the compliance plan to relevant project personnel.

Two emails were evidenced at verifying the distribution of the WDL to key project personnel on 18 June 2014. A further email on 20 June 2014

specifically addresses distributing the compliance plan to the Chief

Engineer for implementation.

In addition to the emails an internal audit was undertaken on the implementation of the Compliance Plan. This was conducted on 12 August 2014 Compliances were identified in all but one element. An action was raised on the finding with measures put in place to rectify the identified gap.

Prior to activity commencing.

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11 The Licensee must ensure the waste water treatment

systems on board the Semac-1 are:

11.1 fit for purpose;

11.2 maintained in accordance with manufacturer’s

specifications; and

11.3 operated by a person competent at operating the

Semac-1 waste water treatment systems.

The Chief Engineer must

oversee all works on the waste

treatment systems and ensure

that a maintenance program is

in place to ensure the system is

fit for purpose.

11.1 Fit for purpose

The Oxford Dictionary defines fit for purpose as well equipped or well

suited for its designated role or purpose.

The purpose of a sewage treatment plant is to remove contaminants from

wastewater effluents. This includes physical, chemical, and biological

processes to remove physical, chemical and biological contaminants.

Its objective is to produce an environmentally safe fluid waste stream. Certificates were evidenced at audit to verify compliance with

System design to comply with IMO Regulations MARPOL MEPC.2 (VI)

Annex IV. The process design has Lloyd’s Type Approval no. 95.00005. The systems each have a hydraulic rating calculated to 200 persons @ 80

litre total blackwater a day. The total persons the Semac-1 is licenced to

carry onboard is 362, well under the system capability. The following certificates were evidenced at audit:

Certificate S1/21.270/95 - Lloyds Register certificate of compliance

with IMO/Marpol MEPC2. (VI) Annex IV for serial numbers

96.008/96.009

Certificate 7634208-2050717-004 – ABS Certificate of compliance

for Sewage Pollution Prevention for the Holland marine sewage

treatment plants onboard Semac-1 as dated 8 October 2011. Both systems underwent a major overhaul prior to mobilising to the Ichthys

project further evidencing that Saipem took all reasonable and practical

measures to ensure that the systems were well equipped and suited for its

designated purpose. Testing obtained during the course of the licence activity conflicted with effluent standards prescribed in the operating manual and IMO/MARPOL standards samples did not accurately reflect measures as they would occur in an open mixing environment. Results obtained from the near field mixing samples verified the rapid dilution of effluent levels upon release into the open water system safeguarding emission of environmentally safe

fluid waste stream minimising any potential for environment or human

health harm.

Prior to mobilisation

and ongoing during

activity

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http://www.oxforddictionaries.com/definition/english/purpose#purpose__6

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11.2 Maintained per manufacturers specifications

Systems maintenance requirements are identified in Section 5 of the

Operating and Instruction Manual. It was verified that the Semac-1 has a

scheduled maintenance program for the WWTP to support manufacturers

requirements to include:

Annual sewage treatment plant inspection

Monthly sewage treatment plant cleaning

3 Monthly check pumps

6 Monthly pump cleaning and greasing

3 Yearly sewage treatment plant painting

3 Yearly pump overhaul

5.1 Sludge pump out was conducted in order with maintenance

specifications in section 5.1.1 with the sludge pump out

conducted prior to entering Darwin Harbour region.

5.2 Chlorine dosage levels were verified as being checked on a

regular basis throughout the duration of the licence activity

period.

5.3 Inlet filter checks are provided for in the 3 monthly checks as

part of the vessel routine maintenance program

5.4 No special maintenance requirements are identified in the

operators manual, however a visual inspection is undertaken

with the quarterly pump inspections.

5.5 A system lay-up was in place prior to the mobilisation of vessel

to project. 11.3 Verification of Competency

The Engineering team onboard the Semac-1 comprises two Chief Engineers and two First Engineers, working rotating shifts. It was verified at audit that engineering team have a combined professional mariner experience in excess of 30 years, with a combined effort of 27 years’ service on the licenced vessel in an engineering capacity.

The Chief Engineers have individually 14 and 2 years’ service onboard the Semac-1 and First Engineers 7 and 4 years respectively. It was verified that the engineering team each have attained adequate hands on experience specifically with the Holland Marine Services MSD-II treatment units to be deemed competent to operate the Semac-1 waste water treatment systems. All personnel are STCW95 certified.

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DISCHARGES AND EMISSIONS

12 This licence authorises wastewater to be discharged from

the discharge point(s) identified in Table 1

Ensure that wastewater discharge is only discharged

from the nominated discharge points

Evidenced drawing DR-S1-0950-EDR-P-03 of the Semac-1 sea water overboard and intake/discharges locations. There is only treated sewage

and greywater discharge line for each system. It was verified that it is not possible to discharge from any other point

During activity in Darwin Harbour and

NT Waters

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13 Waste water(s) discharged from the authorised discharge

points in Table 1 must not:

13.1 contain any visible matter, floating oil and grease or

petroleum hydrocarbon sheen or scum, or litter or other

objectionable matter;

13.2 cause or generate odours which would adversely

affect the use of surrounding waters;

13.3 cause algal blooms;

13.4 cause visible change in the behaviour of fish or other

aquatic organisms;

13.4 cause mortality of fish or other aquatic organisms; or

13.5 cause adverse impacts on plants.

Ensure that discharges do not

contain or cause;

Visible matter

Odours

Algal blooms

Visible change to

surrounding flora or

fauna

Mortality of fish or

aquatic organisms

Adverse impacts on

plants

There has been no known or reported observation(s) of pollution, environmental impact or human health issues identified as a result of these exceedance events.

The project induction was evidenced to include marine mega fauna awareness. Crew are advised of a feedback system in place for the detection of any items of concern in surrounding waters during pipelay activity.

The INPEX customer feedback line report was verified and no concerns raised by the public from pipelay activity during the licenced period

It was further evidenced that a number of support vessels worked close by the Semac-1 during the licenced period. Crew from these vessels had also undergone the project induction and were aware of the need to report any environmental disturbances in the surrounding waters. There were no reported observations during the licensed activity period.

During activity in

Darwin Harbour and

NT Waters

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14 Waste water released from authorised discharge

points must comply with the water quality limits

prescribed in Table 2.

Results from weekly samples

(Condition 19) will provide

limits. These to be tracked

and maintained on a

spreadsheet.

The results spreadsheet was evidenced to record results per: pH 6.5<pH <8.5 Biological oxygen demand (BOD 5 day) 50 mg/L Total suspended solids 50 mg/L Escherichia coli 200 colony forming units per 100 mL Enterococci 200 colony forming units per 100 mL Exceedance limits were identified during the licence period. This was reported to NT EPA upon awareness and is detailed in the non- conformance report.

As results are

returned from the

lab(s)

NC

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15 Discharge of sludge from the Semac-1 waste water

treatment systems to Darwin Harbour waters is not

permitted.

Sludge is not to be discharged

while the vessel is in Darwin

Harbour. This is to extend into NT Waters

post the issue of WDL197-1

It was evidenced at audit that measures were in place to ensure sludge

was not discharged in Darwin Harbour waters.

Maintenance logs were verified to show that tanks were desludged on 10

June 2014, prior to entry into Darwin Harbour limits on 24 June 2014. Furthermore, it was evidenced that additional measures were put in place

to ensure no sludge discharged occurred within NT Territorial Waters. The

work order 2200113724 and 2200113726 verified the next desludge of

tanks being undertaken on the port and starboard tanks on 2 and 3

October 2014 respectively.

NOTE: The amended WDL did not consider desludging in territory waters

the licencee has respected this requirement in favour of complying with

amended licence and regulator jurisdictional boundaries.

Prior to mobilising into

Darwin Harbour, then

ongoing for the

duration of the licence. This is to extend into

NT Waters post the

issue of WDL197-1

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MONITORING

16 The licensee must for all (for on-board) sampling points

required by this Licence:

16.1 install, maintain and provide appropriate

identification signage so that they are easily identifiable at

all times; and

16.2 maintain safe access and egress, as is reasonably

practicable.

Signage to be installed to

identify sampling points. Vessel to ensure that safe

access and egress to the

sampling points is maintained

Photo evidence was verified at audit of signage being placed at the

sampling points.

It is a vessel safety requirement to maintain clean workspaces and ensure

that access and egress is not obstructed.

Prior to mobilising to

Darwin Harbour. Ongoing during the

licence period (and

project)

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17 For each sample required to be collected by this Licence the

following information must be recorded and retained:

17.1 the date(s) on which the sample was taken;

17.2 the time(s) at which the sample was collected;

17.3 the point(s) at which the sample was taken;

17.4 the name of the person who collected the sample;

17.5 the chain of custody forms relating to the sample(s);

17.6 the field measurements and/or analytical results for

the sample; and

17.7 laboratory QA/QC documentation.

Ensure that sample forms

maintain all the required

information.

A sample selection of sample forms were evidenced at audit and it verified

the chain of custody forms from the water microbiology, water chemistry

and ALS laboratories contained detail to include:

date the sample was taken

time sample taken

sample point location

person who took the sample

analytical requirements

Analytical results and laboratory QA/QC were evidenced as included with

the returned results.

As required during

activity

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18 Waste water that is released from the authorised discharge

points defined in Table 1 must be sampled at sampling

points identified in Table 3.

Ensure that samples are taken

from the nominated locations.

It was verified at audit that there is no other sample point location on either

of the WWTP systems.

As required during

activity

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19 Waste water samples collected from sampling points

identified in Table 3 must be analysed for the parameters

identified in Table 4.

Arrange for local lab to

undertake sample analysis on a

weekly basis

Service agreements have been established with local laboratories via URS:

ALS for oil and grease counts;

Dept. of Primary Industries for water chemistry; and

Dept. of Primary Industries for bacteriological analysis.

Arrange prior to

commencement of

activity for the duration

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20 Sampling must be carried out in accordance the AS/NZS

5667.

Ensure vessel has a copy of

AS/NZS 5667 and persons

undertaking the sampling are

aware of the requirements.

The WWTP waste sample collection process was evidenced at audit that

samples were taken to support AS/NZS 5667 requirements to include:

5.1 Samples being take from an outlet on the waste water treatment

plant.

5.2 Stability of sample frequency and timing was maintained as best

practicable to work in with logistics of getting samples from the

vessel via the supply boat to shore.

A selection of sample forms was evidence to show general consistency with the time samples were taken being between

midday and 3pm. Consistency with the frequency samples were

taken was maintained with these initially being of a Wednesday

then increased to Monday/Wednesday and Friday each week.

5.3 It was verified that composite samples were taken.

Sample preservation was maintained to the lowest possible temperature via use of sealed cooler boxes with ice bricks. Furthermore transit times were reduced to as minimal as possible to further preserve temperatures from time the sample was taken to delivery at the labs

Prior to commencing

work in Darwin

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21 The Licensee shall ensure that all water samples are

submitted to a laboratory with current NATA

accreditation for the analysis specified, and analysed in

accordance with the current “Standard Methods for

Examination of Water and Wastewater, APHA-AWWA-

WEF”.

Ensure that:

1. labs have the correct NATA

accreditation and analysis

complies with “Standard Methods

for Examination of Water and

Wastewater, APHA- AWWA-WEF

All labs evidenced to have current accreditation as per: Water Chemistry Accreditation

DPIF – Water Chemistry Lab

NATA Accreditation No. 15104 (2 Dec 13)

ISO/IEC 17025:2005

Water chemistry DPIF – Water Microbiology Lab

NATA Accreditation No. – 15606 (20 Jun 11) ISO/IEC

17025:2005

Microbiological - ALS Environmental Lab

NATA Accreditation No. – 825 (4 Sep 14)

ISO/IEC 17025

Water chemistry and oil and grease samples were verified as being

analysed using methods per APHA’s Standard Methods for Examination

of Water and Wastewater.

Water microbiology analysis use AS4276.21 AND ATSM D 6503-99 for

ecoli and enterococci analysis respectively. These are the standards they

use for analysis and to which their testing procedures and NATA

accreditation applies. If they were to adopt the APHA standard for the

purpose of these tests to comply with this licence condition requirement

they would be in breach of their NATA accreditation. The DPiF water

microbiology lab is the only lab in Darwin that conduct analysis on ecoli and

enterococci.

OBS

RECORDING AND REPORTING

22 All records required to be kept by this Licence must be in a

legible format.

Ensure documents are readable All records evidence during this audit were found to be in a legible format. Ongoing, as required C

23 The Licensee must keep records of all non-compliances

with this Licence.

Ensure non-compliances are

filed with the project office file

and onboard the vessel.

Copies of non-compliances were evidenced as being maintained in the

project file with the waste discharge licence.

As required during

activity

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24 The Licensee must notify the NT EPA as soon as

practicable, and in any case within 24 hours, of becoming

aware of any non-compliances with this Licence.

Ensure relevant personnel are

of the reporting requirements.

Initial notification of the licence exceedance was under the direction

identified under item 27 with as soon as practicable notification made.

This was initially by phone to Jane Orr at approximately 9am on Tuesday 8 July 2014 then provided in written detail by email to NT Pollution by11:39am WST the same day.

Upon review of the notification NT EPA reverted the limit exceedance to a

non-conformance. Due to the change in category it was not possible to

adhere to the ‘within 24 hours’ from receipt of the lab results but was as

soon as practicable upon becoming aware of the results.

No other non-compliances were observed for the licensed activity during

the licence period.

As required during

activity

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25 Non-compliance notifications required under condition 24

must identify:

25.1 circumstances leading up to the non-compliance;

25.2 the risk to the environment from the non-compliance;

25.3 what actions the Licensee will undertake to mitigate

any environmental harm resulting from the non-compliance;

and

25.4 what corrective actions the Licensee will undertake

to ensure the non-compliance does not occur again.

Ensure non-compliance

notifications detail all these

requirements

The non-conformance was initially treated as an exceedance event and

reported in compliance with the requirements defined in item 27. This notification was evidenced during the audit as containing all required

elements within item 25.

As required during

activity

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26 The Licensee must as soon as practicable report to the NT

EPA, all exceedances of the limits specified in Table 2.

Ensure any exceedances are

reported to the NT EPA as soon

as practicable

As evidenced in item 24 above, in light of this limit exceedance being

partial return of results and a full assessment of results for that day would

not be possible until all results were returned, initial notification was made

via phone to Jane Orr at approximately 9am on Tuesday 8 July 2014. Lab results from 3 July 2014 had been received on Monday 7 July 2014.

As only partial results had been returned the Environment team discussed

possible reasons for this anomaly with the Chief Engineer and ways to

manage it prior to alerting others within the Project team early Tuesday

morning.

Email notification was submitted to NT Pollution email at 11:39am WST 8

July 2014.

Notification of results to NT EPA continued as they were returned from the

labs. Due to the intermittent return of results combining with assessment

of new controls in place to manage the system dosage the sharing of

results with the NT EPA was change to set intervals at the end of July for

the remainder of licence activity period.

As required during

activity

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27 Exceedance reports required under condition 26 must

identify:

27.1 potential contributing factors (e.g. operational,

environmental);

27.2 the likely risk of environmental harm arising from the

exceedance; and

27.3 any management actions taken.

Ensure exceedance reports

detail all these requirements

The exceedance event notification was evidenced as containing this

required information.

As required during

activity

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28 The Licensee must immediately and in any case within 24

hours notify the NT EPA of any potential or actual

environmental harm or pollution by contacting the Pollution

Hotline on telephone number 1800 064 567 and emailing

[email protected].

Ensure any identified evidence

of environmental harm is

provided within 24 hours

reports detail all these

requirements

No environmental harm was evidenced from the vessel during the licenced

activity so there was no cause for notification to be evidenced at audit. As identified in item 13 the INPEX customer feedback line report and other project vessels verified that no environmental concerns were identified during the licenced period.

As required during

activity

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29 The Licensee must comply with the requirements of section

14 of the WMPCA.

Ensure that all incidents are duly

reported to the NT EPA.

It was verified at audit that the licensed activity did not present any

incidents to include:

accidents, emergencies or malfunctions; and/or

any deliberate actions by the Semac-1 or persons onboard.

It was evidence that the requirements of the WMPC Act were available to

project personnel in the event of an incident occurrence.

As required during

activity

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30 The Licensee must provide a Monitoring Report to the NT Monitoring report to be At the time of audit this was in development to achieve a submission to NT Within 2 months of C

EPA within two calendar months after completion of the completed and submitted to NT EPA by 30 November 2014. completion of activity –

Activity, noting that the NT EPA may require the Licensee to EPA within two months of 1 December 2014

revise, amend and/or resubmit the report. completion of activity

31

The Monitoring Report must include:

31.1 results of all monitoring and records required under

this Licence; and

31.2 assessment of likely impact to the Darwin Harbour

Water Quality Objectives for the water quality parameters

measured.

32 The Licensee must complete the attached Audit and

Compliance Report (Appendix C), and provide it to the NT

EPA within two calendar months after completion of the

Activity, noting that the NT EPA may require the Licensee to

revise, amend and/or resubmit the Audit and Compliance

Report.

Audit and compliance report

submitted to NT EPA within two

months of completion of activity

As is provided in this audit and compliance report. Within 2 months of

completion of activity –

1 December 2014

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mailto:[email protected].

Engineering, Procurement, Construction and Installation of Gas Export Pipeline (GEP) for Ichthys Gas Field Development

Contract No. 800168

Appendix B Compliance Plan Audit Report

800168-AH-REP-0025

WDL197 AUDIT AND COMPLIANCE REPORT

Page 19 of 35 Rev. 0

THIS PAGE HAS INTENTIONALLY BEEN LEFT BLANK

REGULATORY COMPLIANCE AUDIT REPORT

Audit No. 800168-RC-AUD-001 Date of Audit 12 AUGUST 2014

o:\projects\ichthys\hsesr\3. regulatory\1. gep compliance documents\7. gep audits\rc-aud-001\rc-aud-001 wdl197.docx Page 1/5

AUDIT SCOPE: WLD197 Compliance Plan TYPE OF AUDIT: Practice Audit

AUDIT CLIENT: Semac-1 AUDITOR: Carolyne Leyden

AUDIT OBJECTIVE: To ensure compliance with WDL197 compliance plan requirements.

AUDIT CRITERIA: NT EPA Waste Discharge Licence197

AUDIT METHODOLOGY:

This will be a desktop audit whereby evidence will be gathered from email request and verified for compliance with WDL197 Compliance Plan (Attachment I).

Ref Element Comments Evidence Finding

Water sampling and testing

1. Treated wastewater sampling and analysis (Singapore). Frequency: Once off (March 2014)

Sampling and analysis of the WWTP was conducted in May 2014.

1. Results May 14.pdf

C

2. Treated wastewater monitoring during pipelay in Darwin Harbour (Environmental Coordinator/Semac-1 HSE Advisor). Samples will be analysed by a certified laboratory and collected in accordance with laboratory preservation and holding time requirements. Samples will be analysed for:

- pH - Biological Oxygen Demand (BOD5) - Total Nitrogen - Total Phosphorous - Thermo tolerant coliforms - Total Suspended Solids (TSS) - Chemical Oxygen Demand (COD) - Free chlorine

Weekly lab testing commenced on Thursday 3 July 2014

This was increased to thrice weekly (M-W-F) from 9 July 2014. The increase was a NT EPA requirement post the limit exceedance reported on 8 July 2014.

Copies of results, as received, are shared with NT EPA (M-W-F). Technical oversights are sent (T-Th) each week from 30 July 2014.

The lab sample forms detail what time results are taken and received at the lab. Evidenced a sample selection of forms from:

Refer to results file

..\..\..\..\2.1. Environment\3.5 Licences Permits\Waste Discharge Licence\Results

Testing Results.xlsx

Lab Sample Forms

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1.%20Results%20May%2014.pdf

../../../../2.1.%20Environment/3.5%20Licences%20Permits/Waste%20Discharge%20Licence/Results



../../../../2.1.%20Environment/3.5%20Licences%20Permits/Waste%20Discharge%20Licence/Sampling%20forms




Frequency: Weekly 3 July 2014

16 July 2014

21 July 2014

28 July 2014

6 August 2014

Holding times

BOD 6hrs

COD 7 days

Oil and grease 28 days

Nitrogen 1 day

Suspended solids 7 days

Turbidity 1 day

Phosphorus 28 days

E.coli and Enterococci 12 hrs

Chain of custody forms evidenced at audit verified that samples were received at all labs within an average of 4 hours meeting holding time requirements.

Operations

3. Routine operations checks of treatment system and recorded in the work log by Chief Engineer. Frequency: Minimum of once every shift

Evidenced Chief Engineer’s diary logs from:

5 July 2014

14 July 2014

17 July 2014

Verified these contain WWTP system check.

3. CE Diary of maintenance checks.pdf

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4. Sewage treatment plant maintenance includes: - Enzyme addition - Chemical pump maintenance - Replacement of equipment as required (seals,

bearings, flanges etc.) Frequency: Monthly

Maintenance log evidence to support scheduled monthly maintenance checks done.

23 April 2014

3 Month pump check

6 Month lube clean

4. Scheduled maintenance.pdf C

3.%20CE%20Diary%20of%20maintenance%20checks.pdf

3.%20CE%20Diary%20of%20maintenance%20checks.pdf

4.%20Scheduled%20maintenance.pdf




20 May 2014

Monthly clean

Chemical dosage pump

6 Month maintenance check

19 June 2014

Enzyme addition

5. Warning signs on toilets about not placing foreign objects / substances in the toilets (with the exception of toilet paper). Frequency: Prior to arrival in Darwin Harbour

A warning notice has been placed near toilets not to place foreign objects in toilet bowl

5. Toilet notice.jpg

C

6. Signage will be displayed stipulating, as per the manual that disinfectants should not be used or disposed of via toilets

Frequency: Prior to arrival in Darwin Harbour

A warning notice has been placed near toilets not to dispose of disinfectants in WC system

6. Notice - WC Disinfectants.jpg

C

Sludge Management

7. Tanks desludged. (Not to be undertaken while in Darwin Harbour.) Activity recorded in work log by Chief Engineer.

Frequency: Prior to arrival in Darwin Harbour

Evidenced Chief Engineers work log diary from 15 and 16 June 2014 to verify port and starboard tanks as being desludged on these days.

Semac-1 mobilised to Darwin Harbour on 26 June 2014.

7. Workbooks 16-17 June.pdf C

Training and Communication

8. Awareness of treatment system and operating conditions included in inductions for all personnel

Frequency: Ongoing

Unable to demonstrate that detail on the treatment system and operating conditions were included in the vessel induction.

NC

N Periodic topic for inclusion in pre-start and toolbox meetings

Frequency: Ongoing

Sewerage system included in pre-start meetings:

1 August 2014

17 August 2014

28 August 2014 There was no evidence of the waste treatment system being included in toolbox meetings. These are held prior to a specific task of job being carried out with whoever is involved in the task directly which is not applicable to the

9. Pre-Start Bulletin 1 Aug 14.pdf



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5.%20Toilet%20notice.jpg

6.%20Notice%20-%20WC%20Disinfectants.jpg

6.%20Notice%20-%20WC%20Disinfectants.jpg

7.%20Workbooks%2016-17%20June.pdf

9.%20Pre-Start%20Bulletin%201%20Aug%2014.pdf









WWTP. The chief engineer is the only person to work on this and is well versed with the system.

Compliance Checks

10. Review of all records inspections and monitoring results to be undertaken.

Frequency: Weekly

First samples taken 3 July 2014 with results taking between 2 and 14 days to be returned. Initial bacteriological resulted returned 7 July showing higher e-coli and enterococci limits and consequently reported to NT EPA. This prompted staggered review of results as they were returned, taking between 2 and 10 days to be received. From 30 July 2014 priority analysis commenced in order to better streamline the compliance checks to manage the limit exceedance. Lab results are collated and sent to NT EPA three times weekly (M-W-F) as well as a technical oversight conducted by independent consultant twice weekly (T-Th) and reported to NT EPA.

Completed analysis to be stored in

O:\Projects\ICHTHYS\HSESR\2.1. Environment\3.5 Licences Permits\Waste Discharge Licence

C

Reporting

11. Compliance checks results reported to Semac-1 Master and HSE Manager (Vessel HSE Advisor/ Environmental Coordinator)

Frequency: Weekly

The vessel master and HSE Manger have been heavily involved in communications re the WDL197 limit exceedance, and communications in addressing the issue with the Chief Engineer and the NT EPA.

Evidenced both as being in the cc field of the technical oversight memo sent 12 August 2014.

11. Technical memo email 12-Aug-14.pdf

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12. Non-compliances to be reported to the NT EPA. (Semac-1 Engineer to Semac Captain and HSE Manager. HSE Manager to NT EPA.)

Frequency: As required

Exceedance reported to NT EPA. Refer to limit exceedance communications.

Due to the nature of results coming through to the project office and identified there first.

..\..\3. GEP Approvals\GEP NCRs\NCO 1 - WWTP

C

11.%20Technical%20memo%20email%2012-Aug-14.pdf

11.%20Technical%20memo%20email%2012-Aug-14.pdf

../../3.%20GEP%20Approvals/GEP%20NCRs/NCO%201%20-%20WWTP

../../3.%20GEP%20Approvals/GEP%20NCRs/NCO%201%20-%20WWTP




Observations / Opportunity for Improvement / Non Conformances:

Reference Finding Action required Responsible Person Due Date

8. Information on the WWTS had not been included in the induction

Due to the timing of this being post mobilisation of crew it wouldn’t be purposeful adding this to the vessel induction in retrospect.

Ensure information on the WWTS is included in pre-start/toolbox meetings.

J Pederick 31 August 2014

SIGNED: CAROLYNE LEYDEN REGULATORY COMPLIANCE COORDINATOR 12 AUGUST 2014 Name Position Date

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