mallacoota ocean access boat ramp at bastion point … · independent compliance audit of...

ENV IRONMENTA L ASSESSMENT & NAT URAL RESOURCE MANA GEM ENT

C O N S U L T A N T S

MALLACOOTA OCEAN ACCESS BOAT RAMP at BASTION POINT

Independent Compliance Audit of Environmental Management Plan

2018 Operation and Maintenance FINAL AUDIT REPORT

Prepared For:

East Gippsland Shire April, 2019

Mallacoota Ocean Access Boat Ramp - Bastion Point: Independent Compliance Audit of Operation and Maintenance Environmental Management Plan - 2018

East Gippsland Shire

ETHOS NRM

E N V I R O N M E N T A L A S S E S S M E N T & N A T U R A L R E S O U R C E M A N A G E M E N T

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ETHOS NRM Pty Ltd

ABN: 44 104 999 528

PO Box 204, 162 Macleod St Bairnsdale, Vic. 3875 Telephone: 03-5153 0037 Facsimile: 03-5153 0038 E-mail: [email protected] Website: www.ethosnrm.com.au

Cover Photo: Kelp accumulation at Mallacoota Ocean Access Boat Ramp, Bastion Point, May, 2018

Ethos NRM Pty Ltd Document Control

Client East Gippsland Shire

Title Mallacoota Ocean Access - Bastion Point Boat Ramp: Independent Audit of Environmental Management Plan 2018 Operation and Maintenance. Final Audit Report.

Author Eric Sjerp

Manager Eric Sjerp

Reviewed Internally

Version Final v2.1

Electronic File Name 19001 egsc bastion point emp audit 2018 final v2.1

Date Last Saved 24th April 2019

Date Last Printed No. Vers. / Format Date

Distribution: Internal review 1 Draft v1.0 April, 2019

Tom Weatherall – East Gippsland Shire 1 Draft v1.1 17th April 2019

Tom Weatherall – East Gippsland Shire PDF Final v2.1 24th April 2019

mailto:[email protected]

http://www.ethosnrm.com.au/



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TABLE OF CONTENTS

EXECUTIVE SUMMARY ................................................................................................. 4

1 INTRODUCTION ........................................................................................................ 5

1.1 MALLACOOTA OCEAN ACCESS BOAT RAMP .............................................................. 5 1.2 OPERATION AND MAINTENANCE ENVIRONMENTAL MANAGEMENT PLAN ...................... 5 1.3 AUDITOR’S STATEMENT ........................................................................................... 6

2 INDEPENDENT AUDIT .............................................................................................. 7

2.1 AUDIT SCOPE AND OBJECTIVE ................................................................................. 7 2.2 AUDIT PERIOD ........................................................................................................ 8 2.3 OPERATIONS AND MAINTENANCE ACTIVITIES ............................................................ 8

2.3.1 Area of Operations and Maintenance ............................................................ 8 2.3.2 Definitions and Activities ................................................................................ 9

2.4 AUDIT METHODOLOGY AND STANDARDS .................................................................. 9 2.5 AUDIT MEETINGS, AUDIT EVIDENCE AND SITE INSPECTIONS .................................... 10 2.6 COMPLIANCE RANKINGS ........................................................................................ 11

3 DECLARED NON-CONFORMANCES ......................................................................11

4 AUDIT FINDINGS .....................................................................................................12

4.1 AUDIT CRITERIA .................................................................................................... 12 4.2 AUDIT FINDINGS ................................................................................................... 12 4.3 POSITIVE AUDIT OUTCOMES .................................................................................. 15 4.4 NON-COMPLIANCES .............................................................................................. 16 4.5 AREAS FOR IMPROVEMENT .................................................................................... 16 4.6 PREVIOUS AUDIT FINDINGS ................................................................................... 19

5 CONCLUSION ..........................................................................................................20

6 REFERENCES ..........................................................................................................23

7 APPENDIX 1: DETAILED AUDIT FINDINGS............................................................24

TABLES

Table 1: Compliance Ranking Definitions

Table 2: Summary of Audit Criteria Compliance Findings

Table 3: Recommended Improvements

PLOTS

Plot 1: MOABR O&M EMP Compliance Results for 2018

Plot 2: Comparison of Previous Audit Results



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ABBREVIATIONS

CEMP Construction Environmental Management Plan

CMA Coastal Management Act

DELWP Department of Environment Land Water and Planning (formerly DEPI)

DEPI Department of Primary Industries (now DELWP)

DoEE Department of Environment and Energy (Commonwealth)

EGSC East Gippsland Shire Council

EMP Environmental Management Plan

EPBC Environment Protection and Biodiversity Conservation Act 1999

GPM GPM Construction Pty Ltd

GP Gippsland Ports

MOA Mallacoota Ocean Access

MOABR Mallacoota Ocean Access Boat Ramp

O&M EMP Operations and Maintenance Environmental Management Plan

PDS Project Delivery Standards (also referred to as Audit Criteria)



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EXECUTIVE SUMMARY

Mallacoota Ocean Access Boat Ramp was constructed in 2014 by East Gippsland Shire to facilitate improved launching facilities and ocean access at Bastion Point for commercial and recreational vessels. The facility became operational in December 2014.

Operation and maintenance of Mallacoota Ocean Access Boat Ramp (MOABR) is subject to a variety of statutory approvals and conditions, which are reflected in an approved Operation and Maintenance Environmental Management Plan (O&M EMP).

This Independent Audit seeks to establish the extent to which operation and maintenance activities undertaken by East Gippsland Shire at MOABR in 2018 comply with the requirements of the O&M EMP. The Independent Audit is not an assessment of the boat ramp design or environmental values at Bastion Point. The Audit relates only to an assessment of compliance with the approved MOABR O&M EMP. Similar audits were undertaken for the 2015, 2016 and 2017 operation and maintenance activities (Ethos NRM, 2017a & 2017b, 2018).

All Audit Criteria (or Project Delivery Standards) within the O&M EMP have been assessed by the Auditor against agreed Compliance Rankings (Table 1). A summary of the Audit Findings is presented in Table 2 and below. Appendix 1 lists Audit findings.

Based on the evidence made available by East Gippsland Shire and on-site inspections, the Auditor found 55.9% of the assessed criteria to be either Fully Compliant, or Compliant but Improvements Required, with a further 29.4% showing a Minor Non-Compliance. There were no Critical Non-Compliances nor Major Non-Compliance audit findings for 2018. Compared to previous audits, the Auditor again found a considerable lack of documentation, and whilst there has been a steady reduction in the number of Compliant but Improvements Required results, there is still scope for further improvement relating to operational & maintenance activities at MOABR.

In summary: 47.1% of Audit Criteria are Fully Compliant (16 out of 34)

8.8% of Audit Criteria are Compliant but Improvements Required (3 out of 34)

29.4% of Audit Criteria are a Minor Non-Compliance (10 out of 34)

0.0% of Audit Criteria are a Major Non-Compliance (0 out of 34)

0% of Audit Criteria are a Critical Non-Compliance (0 out of 34)

14.7% of Audit Criteria are Undetermined due to lack of Evidence (5 out of 34)

47.1% 8.8%

29.4%

0.0% 0.0%

14.7%

Fully Compliant

Compliant

Minor Non-Compliance

Major Non-Compliance

Critical Non-Compliance



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1 INTRODUCTION

Ocean access for vessels at Mallacoota was enhanced in 2014 through construction of a new boat ramp facility at Bastion Point. Ethos NRM Pty Ltd, Environmental Assessment and Natural Resource Management Consultants have been engaged by East Gippsland Shire Council to undertake an independent compliance audit of the Operation and Maintenance Environmental Management Plan applicable to operation and maintenance of the ocean access boat ramp at Mallacoota.

This Audit Report covers the 2018 calendar year period. Previous similar audits have been undertaken by Ethos NRM for the 2015, 2016 and 2017 periods (Ethos NRM, 2017a, 2017b, 2018). For comparison purposes, all Mallacoota Ocean Access Boat Ramp audit reports by Ethos NRM follow a similar format and content.

1.1 Mallacoota Ocean Access Boat Ramp

Mallacoota Ocean Access Boat Ramp (MOABR) was constructed by East Gippsland Shire to facilitate improved launching facilities and ocean access at Bastion Point for commercial and recreational craft up to approximately 10 metres in length.

An existing boat ramp at Bastion Point was historically used by recreational fishers, commercial Abalone divers, fisheries patrols, emergency response agencies, Victorian Water Police, Coast Guard, and for servicing Gabo Island. The original boat ramp was used intensively during summer and Easter holiday periods, resulting in car and boat trailer parking often reaching capacity.

Bastion Point is also a popular surfing location and recreational swimming / beach bathing spot for both local residents and tourists.

Construction of the Mallacoota Ocean Access Boat Ramp at Bastion Point was undertaken under contract by GPM Constructions on behalf of East Gippsland Shire. Construction was completed in December 2014.

Ongoing operation and maintenance of the boat ramp facility is the responsibility of East Gippsland Shire, and is undertaken in accordance with various regulatory approvals and an Operation and Maintenance Environmental Management Plan (O&M EMP).

1.2 Operation and Maintenance Environmental Management Plan

Operation and maintenance of the Mallacoota Ocean Access Boat Ramp at Bastion Point is subject to a variety of statutory approvals which originate from a 2009 Ministerial Assessment of the Mallacoota Ocean Access Boat Ramp Environmental Effects Statement and subsequent Coastal Management Act Consent (DELWP, 2013). Conditions contained within these approvals are reflected in the Operation and Maintenance Environmental Management Plan.

The O&M EMP outlines the environmental management requirements to be complied with during operation and maintenance of the Ocean Access Boat Ramp and its related infrastructure at Bastion Point, Mallacoota.

Version ‘Final V2’ dated 1st December 2014 (Crossco, 2014) is the most recent O&M EMP document and forms the basis of this Audit. It is based on an earlier approved Plan (Version 5, dated 6th November, 2014) that addressed both construction and operation & maintenance requirements. The current ‘Final V2’ O&M EMP document only addresses operation & maintenance requirements.



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Environmental and statutory approvals addressed by the O&M EMP include the Environment Protection and Biodiversity Conservation Act 1999 (Commonwealth), Environment Effects Act 1978, Coastal Management Act 1995, Environment Protection Act 1970, and the Planning and Environment Act 1987.

The O&M EMP comprises several parts/sections based on general requirements, operational and maintenance aspects, and an environmental risk assessment and register. In summary the approved EMP includes:

• Performance requirements for environmental management during the operational phase (post-construction) of the boat ramp;

• Performance requirements for environmental management of maintenance activities undertaken during the operational phase of the boat ramp;

• Risk assessment framework and project risk register; • Environmental objectives and targets for different components of the operation and

maintenance works; • Environmental controls, including standards and limits, to ensure that specific

objectives and targets are achieved; and • Responsibilities for implementing the EMP.

The Environmental Risk Assessment and Register included in Appendix 5 of the O&M EMP provides an evidence-based assessment of the potential impacts from construction and operational activities upon specific environmental values. The risk treatment / mitigation measures identified in the Environmental Risk Assessment are reflected as environmental controls in the O&M EMP.

Key values and risk events identified in the Risk Assessment and Register are:

• Airborne noise; • Coastal ecology and habitat; • Terrestrial habitat; and • Removal of native vegetation.

Specific environmental performance standards and targets to address the various risks are referred to as Project Delivery Standards (PDS) and Environmental Controls in the O&M EMP.

East Gippsland Shire, as the ‘owner and operator’ of Mallacoota Ocean Access Boat Ramp, is responsible for ensuring that all operational and maintenance activities relating to the MOABR comply with the O&M EMP. Council staff are responsible for day-to-day activities, and engage consultants / contractors for specialist tasks.

1.3 Auditor’s Statement

This Independent Audit has been completed in accordance with a Project / Audit Brief and is generally consistent with the requirements of ISO19011:2014. The Auditor is suitably qualified, experienced and competent to undertake the audit.

Ethos NRM has previously completed a variety work for East Gippsland Shire Council (EGSC), including:

Independent Compliance Audit of Environmental Management Plan for both

construction and for operation & maintenance of Mallacoota Ocean Access Boat

Ramp

Development of management plans for foreshore, recreation / open space and

ecologically sensitive areas managed by EGSC;



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Development and involvement in preparation of environmental and planning

strategies for rural land and ecologically sensitive areas;

Independent reviews and status assessments of previously prepared management

plans;

Independent compliance reviews of previously completed revegetation works; and

Independent assessment and reporting of environmental values and potential

impacts of proposed Council works.

In addition, Ethos NRM regularly prepares environmental impact reports to accompany planning permit applications by third parties, which are then subsequently assessed by Council statutory planning staff for approval.

Ethos NRM has had no direct involvement in undertaking environmental assessments, reporting or gaining approvals associated with establishment or operation of the MOABR. Ethos NRM did provide Council with advice regarding the scope and content of the original 2015 Project/Audit Brief for MOABR audits.

East Gippsland Shire Council and Ethos NRM both assessed the potential for a conflict of interest, and concluded that the previous work by Ethos NRM in no way compromises the independence of Ethos NRM in undertaking this audit, nor does the previous work constitute a Conflict of Interest.

2 INDEPENDENT AUDIT

2.1 Audit Scope and Objective

This Independent Audit seeks to establish the extent to which operation and maintenance of the Mallacoota Ocean Access Boat Ramp complies with the requirements of the O&M EMP.

The Objectives of the Independent Audit, as specified in the Audit Brief (East Gippsland Shire Council, February, 2018), is to:

1. Undertake an independent compliance audit of the approved EMP including:

independently assess implementation of the EMP; and

independently gather information that verifies compliance against all the

Environmental Controls specified in the EMP.

2. Advise East Gippsland Shire of any non-conformances with the EMP.

3. Provide a written audit report to East Gippsland Shire outlining:

the extent of compliance against all Environmental Controls specified in the

EMP; and

any potential improvements to the audit process for subsequent ‘operational

and maintenance’ audits.

(Note Council did not issue a detailed for this 2018 audit, instead issued an ‘email brief’ requesting that the previous Audit Brief be used for reference.)

Importantly, the Audit Brief highlights that the Independent Audit is not an assessment of the boat ramp design or environmental values at Bastion Point. The Audit relates only to an assessment of compliance with the approved MOABR O&M EMP.



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This Independent Audit relates only to the operational and maintenance phase of MOABR. The Audit Brief explicitly excludes auditing of construction aspects, which have been separately audited following completion of the construction phase (Ethos NRM, 2015).

2.2 Audit Period

This Audit Report covers operations and maintenance activities at Mallacoota Ocean Access Boat Ramp for the 2018 calendar year period. This audit was undertaken between March and April, 2019.

Conditions of the Coastal Management Act Consent require that a separate independent operations and maintenance audit is undertaken and reported upon annually.

Previous Audit Reports cover the 2015, 2016 and 2017 periods (Ethos NRM, 2017a, 2017b, 2018).

2.3 Operations and Maintenance Activities

2.3.1 Area of Operations and Maintenance

The area within which Council’s operations and maintenance activities are permitted to occur is defined by a formal Crown Land Lease area on Plan of Crown Allotment OP123390, which is illustrated in Appendix 1 of the O&M EMP, and is reproduced below.



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2.3.2 Definitions and Activities

‘Operations’ is defined in the O&M EMP as:

Operations include the launching and / or retrieval of vessels and temporary berthing of vessels associated with launching and retrieval of vessels. Operational activities will be carried out by commercial, recreational and Government Agency users.

Operations will be undertaken in accordance with the Maritime Safety Operational Manual as required by condition 3 of the Coastal Management Act consent dated 14 January 2013.

‘Maintenance’ is defined in the Audit Brief as:

Maintenance works are defined as works required or undertaken to preserve the infrastructure constructed in good working order, and as near to “as designed” and “as constructed” for as long as possible.

These works may be routine or on an “as required” basis.

Maintenance works are the responsibility of EGSC and will be carried out by or on behalf of EGSC.

Operations and maintenance activities that may occur at MOABR are listed in Appendix 1 of the O&M EMP, and include but are not necessarily limited to:

Establish environmental & cultural heritage management controls and OHS in

accordance with approved plans

Removal of sand and/or kelp from boat ramp

Landscaping

Timber structures (jetty, bollards, walkway)

Roadways and pedestrian access paths

Breakwater

Navigational aids

Ablutions

Lighting

Pavement line marking

Signage

Navigational channel

Servicing infrastructure (electricity, sewer, water)

Parking of vehicles and associated trailers.

2.4 Audit Methodology and Standards

Requirements of AS/NZS ISO 19011:2014 Guidelines for Auditing Management Systems have been used to direct this audit. AS/NZS ISO 19011:2014 provides a clear systematic approach for undertaking audits and allows for a consistent approach across multiple or recurrent audits. Definitions used throughout this Audit Report are generally consistent with AS/NZS ISO 19011:2014.

The audit methodology is consistent with the Audit Brief issued by Council and with the Coastal Management Act Consent conditions stipulated by the Department of Environment Land Water and Planning (DELWP, 2013).



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The environmental requirements, standards and limits assessed by this audit are listed as ‘Project Delivery Standards’ (PDS) and ‘Environmental Controls’ in the O&M EMP, and are referred to in this report as Audit Criteria for the purposes of assessing compliance with the O&M EMP. The individual Audit Criteria are listed in the ‘Register of Environmental Objectives and Targets’ of the O&M EMP (Table 4 to Table 10, Appendix 4), and in Table 3 of the O&M EMP.

An Audit Plan was developed in cooperation with East Gippsland Shire Council staff to direct specific audit tasks and to ensure the audit objectives and methodology were clear.

The audit methodology involved:

Audit Commencement Meeting

o Agreed Audit Plan

o Confirmation of Audit Criteria

o Confirmation of compliance rankings

Exchange of audit evidence and related information

Audit meetings

On-site inspection at Bastion Point

Audit assessment

Issuing of Draft Audit Findings

Issuing of Final Audit Findings

Audit Closure

2.5 Audit Meetings, Audit Evidence and Site Inspections

An audit inception / commencement meeting was held on 14th March 2019, where the Draft Audit Plan, method and Audit Criteria were confirmed.

Subsequent meetings, phone calls and email exchanges took place over the following weeks in order to facilitate the transfer and assessment of information and Audit Evidence provided by Council staff, and to discuss recommendations made in the previous MOAB compliance audits (2015, 2016 and 2017) for a range of improvements.

All available evidence was freely provided by EGSC to the Auditor.

A site inspection and meeting was undertaken at Mallacoota by Ethos NRM on 19th March, 2019, which afforded the Auditor with first-hand observational evidence of the boat ramp, dredging equipment, and the Catfish dredge vessel which was located at the EGSC depot.

Assessment of Audit Evidence occurred in March and April 2019.

The Auditor also benefited from his familiarity of the general Bastion Point boat ramp environs, having visited the site on numerous occasions before and subsequent to this audit, for matters other than this audit. These occasions allowed the Auditor to observe day-to-day operational aspects of the boat ramp.

A draft Audit report was issued to East Gippsland Shire on 17th April, 2019.

A Final Audit report, incorporating minor text edits, was issued to East Gippsland Shire on 24th April, 2019, and Audit Closure is expected to occur in late April, 2019.



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2.6 Compliance Rankings

Compliance Rankings and definitions listed in the Audit Brief were confirmed at the Commencement Meeting as being appropriate for use in undertaking a compliance audit of the O&M EMP.

Table 1 below lists the adopted compliance rankings.

The ranking applied to an O&M EMP non-conformance (ie Minor, Major or Critical), was determined by assessing the extent to which the non-conformance impacts on environmental values, as outlined in the Environmental Risk Register included in Appendix 5 of the O&M EMP, and with the regulatory (legal) approvals governing that specific non-conformance.

Table 1: Compliance Ranking Definitions

Compliance Rank / Grade

Description

Fully Compliant There is sufficient evidence to confirm that actions have been undertaken, prepared and/or implemented in full compliance with the requirements of the auditable element.

Compliant but with Improvements Required

There is evidence to confirm that actions have been implemented to achieve compliance with the auditable element, but improvements are required to achieve Full Compliance.


The evidence shows that actions are not in full compliance with the requirements of the auditable element but it is unlikely that this will cause the environment to be seriously affected.


The evidence shows that actions are not in full compliance with the requirements of the auditable element and this gives risk to a high potential that the environment will be seriously affected if the non-compliance is not rectified.


The evidence shows that actions are not in full compliance with the requirements of the auditable element and this gives rise to a serious or imminent risk to the environment.

Undetermined There is insufficient evidence to make a judgement on compliance.

Not Applicable The auditable element falls outside the scope of the audit, eg. work relevant to the environmental control/standard has not yet commenced.

3 DECLARED NON-CONFORMANCES

During the commencement and audit meetings, East Gippsland Shire staff indicated that there had been a single operational incident during 2018. This involved a minor hydraulic leak on the Catfish dredge whilst the vessel was operating. Details are provided under Audit Criteria 20, in the Detailed Audit Findings (Appendix 1).

In addition Council staff also indicated that there was an unannounced site visit by WorkSafe Victoria that resulted in a Compliance Notice being issued. Details are described in Audit Criteria 6, in the Detailed Audit Findings (Appendix 1).



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4 AUDIT FINDINGS

4.1 Audit Criteria

The environmental requirements, standards and limits evaluated by this audit are listed as Project Delivery Standards and Environmental Controls in the MOABR O&M EMP, and are referred to in this audit report as Audit Criteria for the purposes of assessing compliance with the O&M EMP.

Detailed Project Delivery Standards and Environmental Controls are listed in Table 4 to Table 10 of the ‘Register of Environmental Objectives and Targets’, Appendix 4 of the O&M EMP. The tables address the following Audit Criteria themes:

General Management of Maintenance Activities

Marine-based works

Dredging / excavation and plume

Channel maintenance schedule

Dredged / excavated material management

Land based standards

Additional Audit Criteria listed in Table 3 of the O&M EMP relate to External Notification and Reporting.

A summary of the Audit Criteria assessed for this Audit are listed in Table 2 of this report, with further detail provided in Appendix 1 (Detailed Audit Findings).

4.2 Audit Findings

A detailed assessment of compliance against all Audit Criteria is documented in Appendix 1: Detailed Audit Findings.

Audit findings are summarised in Table 2 below. Findings are listed only for the 2018 operational and maintenance phase of the MOABR. An audit of construction activities was completed separately in 2015 (Ethos NRM, 2015), and previous operational and maintenance audits for 2015, 2016 and 2017 were reported on separately (Ethos NRM 2017a; Ethos NRM 2017b, Ethos NRM 2018).

A total of thirty four (x34) Audit Criteria have been assessed by the Auditor, with the following results (excluding three (x3) additional Not Applicable results), which are also depicted in Plot 1:

47.1% of Audit Criteria are Fully Compliant (16 out of 34)




0.0% of Audit Criteria are a Critical Non-Compliance (0 out of 34)


Excludes Audit Criteria that are Not Applicable (3 criteria)



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Less than half (47.1%) of the assessed Audit Criteria are Fully Compliant, and approximately one tenth (8.8%) are Compliant but Require Improvements.

There are no Critical Non-Compliances and no Major Non-Compliance. However, a significant proportion of Audit Criteria (29.4%) are a Minor Non-Compliance.

In addition, a considerable proportion of Audit Criteria (14.7%) were Undetermined due to a lack of Audit Evidence.

An initial Major Non-Compliance finding (for Audit Criteria 7a) was presented to EGSC staff in the Draft Audit Report, but was upon review of the O&M EMP, amended to Not Applicable, with a recommendation to clarify the O&M EMP intent.

Plot 1: MOABR O&M EMP Compliance Results for 2018

These 2018 Audit Findings are similar to the results determined for 2015, 2016 and 2017 (see Plot 2), although there has been a slight improvement in the number of Fully Compliant results and a slight increase in the number of Minor Non-Compliance audit findings, with a corresponding reduction compared to previous years in the Compliant but Improvement Required.

The underlying cause of these changes and lack of substantial improvement is canvased in the Discussion Section below.

47.1%

8.8%

29.4%

0.0% 0.0%

14.7% Fully Compliant

Compliant




Undetermined



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Table 2: Summary of Audit Criteria Compliance Findings for 2017

Audit Criteria

Fu

lly

Co

mp

lia

nt

Co

mp

lia

nt

bu

t

imp

rovem

en

ts

req

uire

d

Min

or

No

n-

Co

mp

lia

nc

e

Ma

jor

No

n-

Co

mp

lia

nc

e

Cri

tic

al

No

n-

Co

mp

lia

nc

e

Un

de

term

ine

d

(du

e t

o la

ck

of

Ev

ide

nce

)

No

t

Ap

pli

ca

ble

1. Hours of operation x1

2. Airborne noise x1

3. Waste management x3 x2

4. Equipment maintenance x1

5. Fuels, oils, chemicals and hazardous goods

x1

6. Emergency response preparedness

x1 x1 x1

7. Marine pests x1 X3

8. Vessel Refuelling x1

9. Cetacean – vessel manoeuvring x1

10. Heritage (marine based) – identification of potential relics

x1

11. Dredging / excavators and plume

x2

12. Dredging / excavator schedule x1

13. Consideration of season sensitivities

x1

14. Dredged / excavated material disposal

x1 x1

15. Disposal site monitoring x1

16. Excavation, placement and stockpiling of material

x1

17. 17. Removal and management of native vegetation

x2

Continued …..



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Table 2: continued

Audit Criteria

Fu

lly

Co

mp

lia

nt

Co

mp

lia

nt

bu

t

imp

rovem

en

ts

req

uire

d

Min

or

No

n-

Co

mp

lia

nc

e

Ma

jor

No

n-

Co

mp

lia

nc

e

Cri

tic

al

No

n-

Co

mp

lia

nc

e

Un

de

term

ine

d

No

t

Ap

pli

ca

ble

18. Weeds and pest animals x1 x2

19. Sediment transport control x2

20. External notification and reporting

x2 x1

TOTALS 16 3 10 0 0 5 3

% TOTALS (excl Not Applicable)

47.1% 8.8% 29.4% 0.0% 0.0% 14.7%

4.3 Positive Audit Outcomes

Positive outcomes from this independent compliance audit of the MOABR EMP for operations and maintenance activities at Bastion Point during 2018 are:

Successful operation of EGSC Catfish dredge vessel throughout the year

Continued preparedness and commitment by EGSC on-site operational staff to

operate and maintain MOABR in accordance with the intent of all regulatory

requirements and the MOABR O&M EMP

Successful introduction of Bastion Pt Dredging Operations Work Diary / Log Book

for recording operational details whilst dredge is being operated.

Continued strong working relationship and operational / procedural arrangements

between EGSC on-site operational staff and contractors working at MOABR,

particularly KcKinnon Earth Constructions, Kina Diving, and Environmental Marine

Solutions

No major operational incidents resulting in catastrophic environmental impact

No Critical Non-Compliance and no Major Non-Compliance audit findings

47.1% of assessed Audit Criteria are Fully Compliant

Additional operational details are being recorded by staff on the Weekly Inspection

Logs.

Improvements have been made by acting upon a number of the previous

Recommendations for Improvements.

Successful removal of navigation hazard (dislodged rock) in channel

Details are documented in Appendix 1: Detailed Audit Findings.



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4.4 Non-Compliances

As found in previous independent compliance audits of the MOABR O&M EMP, operation and maintenance of MOABR at Bastion Point has been undertaken professionally and with the correct intent by EGSC staff. However, this audit, (as with previous year’s audits) has identified a variety of adverse findings for the 2018 period, including:

A significant proportion of Audit Criteria (29.4%) are a Minor Non-Compliance

Large proportion (14.7%) of Audit Criteria were Undetermined due to a lack of

Audit Evidence

Improvement is required in relation to 8.8% of assessed Audit Criteria that are

otherwise Compliant

Failure to capture and record all necessary information to demonstrate compliance

Incomplete records of contractor work practices, particularly operational logs, SOP

and SWMS documentation

Lack of documented evidence, primarily from Contractors, relating to:

o storage and handling of fuels, oils, chemicals and hazardous goods,

particularly for contractor’s equipment

o emergency response procedures, including for oil spills, man overboard,

and training

o equipment maintenance

Lack of GPS evidence to demonstrate that all dredging and/or excavation activity

remains within the identified channel zones

Incomplete notification to government agencies of potential and confirmed

environmental incidents.

These Non-compliances are again similar in nature and frequency to the results determined for 2015, 2016 and 2017. Importantly, the non-compliances have not come about due to any wilful act to purposefully avoid compliance with the MOABR O&M EMP. Rather they result from Council establishing work practices – which are often adequate in their own right – but fail to take into account the O&M EMP’s specific requirements for record keeping and documentation.

All Non-Compliances are documented in Appendix 1: Detailed Audit Findings.

4.5 Areas for Improvement

A substantial number of improvements have been identified throughout the Detailed Audit Findings listed in Appendix 1. These recommendations are summarised in Table 3 and reflect both the “Compliant but with Improvements Required” compliance grading, and less critical improvements associated with outcomes that still have scope for improvement during the ongoing operational and maintenance phase of MOABR.

Table 3 covers both i) improvements required of EGSC, and ii) recommendations to review and improve the MOABR O&M EMP.

In summary, improvements required of EGSC focus on ensuring that existing work practices – which (as noted above) are often adequate in their own right – are enhanced to better reflect specific requirements stated the MOABR O&M EMP, and to ensure all the



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necessary information is captured and recorded so that compliance with the Audit Criteria can be easily demonstrated.

Recommendations for review and improvements to the MOABR O&M EMP focus on ensuring the EMP is relevant to the actual type of dredging and excavation being undertaken by EGSC at MOABR, and that it is ‘value adding’ to the overall efficiency of operations and maintenance activities, whilst at all time preventing adverse environmental impacts.

All Areas for Improvement are documented in the Detailed Audit Findings (Appendix 1).

Table 3: Recommended Improvements

Recommendations for Improvements

Improvements Required of EGSC

Develop comprehensive response procedures / arrangements / systems (ie

SOP’s SWMS etc), in co-operation with all staff and contractors, to ensure

sufficient systems are in place to mitigate threat of an oil spill or noxious

substance discharge during operation of any machinery near or over water (eg

dredge, excavators, front-end loaders).

Develop data capture and record keeping protocol to demonstrate maintenance

of all Contractor’s plant and equipment.

Modify EGSC Weekly Inspection Logs and EGSC Bastion Pt Dredging

Operations Work Diary / Log Book to include inspection for all on-site hazardous

materials (including confirmation that none is on-site).

Create Hazardous Substances Register and establish system for documenting

and retaining records of all hazardous materials used by contractors .

Require Contractors to develop and submit “waste management arrangements

to include waste minimization, containment, segregation and appropriate reuse,

recycling, treatment and disposal”.

Develop and test emergency response procedure (including for all contractors),

and retain records in accordance with App 8 & 10 of O&M EMP.

Document staff oil spill response training.

Document existence of oil spill response kits for all contractor’s and equipment.

Develop procedures and data capture / record keeping protocols to minimise the

threat of introducing marine pests from Catfish Dredge and support vessels

being used in waters beyond Mallacoota, including a register of all necessary

decontamination certification.

Implement training to enable staff to identify and report potential marine pests,

particularly when Catfish Dredge is used in waters beyond Mallacoota.

Develop and implement operational procedure for response to Cetacean

sightings during operation of dredge and support vessels.



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Recommendations for Improvements

Continued …..

Develop and implement improved method for recording that all dredging and/or

excavation activity remains within the identified channel zones.

Continue liaison with DELWP to investigate options and gain Coastal

Management Act Consent approval for improvements to dredge / excavated

material disposal site management. Objective should be to prevent ‘circular

flow’ resulting in deposited material being washed southwards back onto boat

ramp apron and back into launching channel.

Prepare a Performance Report to DELWP on management of disposal site,

including options for prevention of ‘circular sand flow’ and deposition of rocks

resulting excavation of shallow areas inaccessible by dredge.

Review and Improve MOABR O&M EMP

Amend O&M EMP to better distinguish allowable work hours for machinery use

(eg dredging) verses routine maintenance (eg toilet cleaning).

Review O&M EMP to consider applicability of Airborne Noise Standard

Review O&M EMP Audit Standard / Criteria 7B to determine if applicable.

Update O&M EMP to reflect most current version of EPA Publication 949, if

remains relevant.

Reword O&M EMP Audit Standard / Criteria 7a to better reflect dredge and

support vessels being used at MOABR.

Review O&M EMP Audit Standard / Criteria 7C to determine if applicable.

Update O&M EMP to reflect most current version of Australian Ballast Water

Management Requirements, if remains relevant.

Update O&E EMP to correctly identify that Crossco Drawing No. 1579/007-B has

been updated to 1579/007-C.

Review O&M EMP Audit Standard / Criteria 11B to better reflect equipment

being used at MOABR.

Review O&M EMP to consider appropriateness of Criteria 18a within O&M EMP

rather than managed thorough corresponding By-Laws. Alternatively, amend

Weekly Inspection Logs to include checks for domestic animal restrictions.

Review O&M EMP to consider appropriateness of “Imported Soil” Criteria within

O&M EMP. Alternatively, amend Weekly Inspection Logs to include checks for

imported soil.

Amend O&M EMP to clarify intent of DELWP ‘Notification’ Audit Criteria.



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4.6 Previous Audit Findings

Audit Findings from previous operational and maintenance activities at MOABR have been documented in three separate reports similar to this audit report, and issued to Council at the conclusion of each audit.

Plot 2 highlights that the 2018 Audit Findings are similar to the results determined for 2015, 2016 and 2017, although there has been a slight improvement in the number of Fully Compliant results and a slight increase in the number of Minor Non-Compliance audit findings, with a corresponding reduction compared to previous years in the Compliant but Improvement Required

The underlying cause of these changes and lack of substantial improvement is canvased in the Discussion Section below.

Plot 2: Comparison of Previous Audit Results

The 2015 and 2016 audit reports were not distributed within Council to either an Audit & Risk Committee, nor to operational staff responsible for day-to-day management of the Mallacoota boat ramp at Bastion Point. The 2017 audit report was circulated internally on only a very limited basis.

MOABR O&M EMP audits do not form part of a broader Annual Audit Plan undertaken by Council, and hence were not subjected to the levels of review and action other similar audit reports commonly adhere to. Consequently there has been no formal process to address previous audit findings, nor put in place the necessary resources to enable staff to make the recommended improvements. The EGSC Works Supervisor responsible for



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MOABR was unaware of previous the Audit Findings until the commencement of the 2017 audit. A Council staff member recently appointed to oversee on-site MOABR activities was not aware of the 2017 Audit Findings.

Hence, whilst some of the previous Audit Findings have been addressed through staff making ‘opportunistic’ improvements, there is still no formal ‘improvement process’ and many of the findings remain ‘Open’. This is reflected by the 2018 Audit Findings again being very similar to those from 2015, 2016 and 2017, including similar Non-compliances and similar Improvements being ‘carried forward’ from previous years.

5 CONCLUSION

Operation and maintenance of the Mallacoota Ocean Access Boat Ramp at Bastion Point during 2018 was subject to a variety of ‘Environmental Controls’ specified in the Mallacoota Ocean Access Boat Ramp Operations and Maintenance Environmental Management Plan (MOABR O&M EMP).

This Independent Audit has assessed thirty four (x34) individual Audit Criteria (ie Standards) to determine compliance of operations and maintenance activities with the requirements of the O&M EMP.

Operation and maintenance activities during 2018 involved dredging, excavation, sand management, ramp cleaning, signage, traffic management, responding to operational incidents, and preparedness to respond to emergency situations.

Based on the evidence made available by East Gippsland Shire and on-site inspections, the Auditor found 55.9% of the assessed criteria to be either Fully Compliant, or Compliant but Improvements Required, with a further 29.4% showing a Minor Non-Compliance. There were no Critical Non-Compliances nor Major Non-Compliance audit findings for 2018.

Compared to previous audits, the Auditor again found a considerable lack of documentation, and whilst there has been a steady reduction in the number of Compliant but Improvements Required results, there is still scope for further improvement relating to operational & maintenance activities at MOABR.

In summary:

47.1% of Audit Criteria are Fully Compliant (16 out of 34)




0.0% of Audit Criteria are a Critical Non-Compliance (0 out of 34)


An additional three Audit Criteria are considered Not Applicable for this audit assessment.



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Areas of Non-Compliance include:

Failure to capture and record all necessary information to demonstrate compliance

Incomplete records of contractor work practices, particularly operational logs, SOP

and SWMS documentation

Lack of documented evidence, primarily from Contractors, relating to:

o storage and handling of fuels, oils, chemicals and hazardous goods,

particularly for contractor’s equipment

o emergency response procedures, including for oil spills, man overboard,

and training

o equipment maintenance

Lack of GPS evidence to demonstrate that all dredging and/or excavation activity

remains within the identified channel zones

Incomplete notification to government agencies of potential and confirmed

environmental incidents.

Recommended improvements focus on ensuring that existing works are enhanced to better reflect specific requirements from the MOABR O&M EMP, and to ensure that all the necessary information is captured and recorded so that compliance with the Audit Criteria can be easily demonstrated.

Recommendations for review and improvements to the MOABR O&M EMP focus on ensuring the EMP is relevant to the actual type of dredging and excavation being undertaken by EGSC at MOABR, and that it is ‘value adding’ to the overall efficiency of operations and maintenance activities whilst at all times preventing adverse environmental impacts. As stated following completion of all previous MOABR audits, the EMP should be substantially edited. Re-grouping the EMP content to combine similar Standards and Controls (ie. Audit Criteria) will provide Council with a better tool to more efficiently record and demonstrate compliance across all the necessary issues. Updating the MOABR O&M EMP will also greatly improve Council’s ability to manage the facility more efficiently.

Importantly, the non-compliances and need for improvements identified in this audit report have not come about due to any wilful act to purposefully avoid compliance with the MOABR O&M EMP. Rather they result from Council staff establishing work practices – which are often adequate in their own right – but fail to take into account the O&M EMP’s specific requirements for record keeping and documentation. East Gippsland Shire’s staff responsible for operation and maintenance of the MOABR at Bastion Point have made a conscious effort to implement improvements, and continue to actively and diligently manage the site with the resources made available to them.

Restricted pedestrians access during dredging operations resulted in several instances where members of the public became hostile and abusive towards Council staff, including an instance in 2018 which required police attention. This no doubt impacts on staff morale and their ability to manage the site efficiently.

The lack of substantial improvement in Fully Compliant audit findings over the four year period between 2015 and 2018 highlights that a review of Council’s management approach at MOABR is required. The O&M EMP should be seen as a tool to assist Council operate the site safely and efficiently, with minimal impact to the surrounding environment. Reviewing and updating the EMP to be better aligned with Council’s operational activities will enable streamlined work practices and accurate record keeping,



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which can be used to readily show compliance with the EMP standards. Including MOABR O&M EMP audits as part of Council’s broader Annual Audit Plan, having increased internal circulation and empowering Council staff with the necessary resources to make improvements, will engender greater ownership and drive a cultural shift towards seeing the EMP and related audits as a useful tool, rather than a burden.

DELWP (as regulator of the Coastal Management Consent for MOABR) have provided only limited feedback on previous Audit Findings. Council should liaise with DELWP and gain their support to transform the O&M EMP and related Audit process into a mutually beneficial undertaking.

The Auditor acknowledges and appreciates the manner in which all relevant information and evidence was made readily and freely available during the course of this Audit.

ERIC SJERP Date: 24th April, 2019 Principal Consultant / Managing Director



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6 REFERENCES

Crossco, 2013. Mallacoota Ocean Access Boat Ramp Environmental Management Plan. Prepared for East Gippsland Shire Council

Crossco, 2014. Operations and Maintenance Environmental Management Plan: Bastion Point, Mallacoota (Final V2, December 2014). Prepared for East Gippsland Shire Council

DELWP, 2013. Coastal Management Act approval, Department of Environment Land Water and Planning, January 2013

East Gippsland Shire, 2019. Audit Brief (email), February 2019

Ethos NRM, 2015. Mallacoota Ocean Access Boat Ramp at Bastion Point: Independent Compliance Audit of (Construction) Environmental Management Plan. Prepared for East Gippsland Shire Council

Ethos NRM, 2017a. Mallacoota Ocean Access Boat Ramp at Bastion Point: Independent Compliance Audit of Environmental Management Plan. 2015 Operation and Maintenance. Prepared for East Gippsland Shire Council

Ethos NRM, 2017b. Mallacoota Ocean Access Boat Ramp at Bastion Point: Independent Compliance Audit of Environmental Management Plan. 2016 Operation and Maintenance. Prepared for East Gippsland Shire Council

Ethos NRM, 2018. Mallacoota Ocean Access Boat Ramp at Bastion Point: Independent Compliance Audit of Environmental Management Plan. 2017 Operation and Maintenance. Prepared for East Gippsland Shire Council



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7 APPENDIX 1: Detailed Audit Findings

Project Delivery Standard /

Audit Criteria Evidence Audit Findings and Comments Compliance

Table 4: GENERAL MANAGEMENT OF MAINTENANCE ACTIVITIES

Objective:

To plan and implement maintenance aspects of MOA.

To ensure materials are appropriately stored, handled and disposed of.

Application:

Throughout all MOA maintenance activities

Target:

Conformance with all environmental limits and controls Operations and Maintenance Risk Register.

1. Hours of operation Evidence Audit Findings and Comments Compliance

a. All activities must be

conducted in accordance

with EPA guidelines, except

where explicitly restricted

within this EMP, or by

legislation.

EGSC Weekly Inspection Logs

EGSC Bastion Pt Dredging Operations Work Diary / Log Book

Copies of EGSC emails regarding operations and maintenance activities

“Maintenance” hours apply to all works required to maintain MOABR facility. O&M EMP makes poor distinction between dredge use, machinery use and other routine maintenance (eg toilet cleaning) outside of specified hours.

Dredging Operations Work Diary / Log Book records the dredge operating hours and indicates which contractor machinery is on site:

KcKinnon Earth Construction – excavator and loader hire and use for sand removal

Environmental Marine Solutions - machinery hire and use for ramp cleaning - Kelp

Kina Diving machinery hire and use for rock hazard removal and underwater inspections

No individual records from separate Contractors were made available, other than several invoices. Available evidence suggests all operations and maintenance activities occurred during daytime.

Fully Compliant



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Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.

Improvement:

Amend O&M EMP to better distinguish allowable work hours for machinery use (eg dredging) verses routine maintenance (eg toilet cleaning).

2. Airborne noise Evidence Audit Findings and Comments Compliance

a. All activities must be

conducted in accordance

with Noise from Industry in

Rural Victoria (NIRV: EPA

Publication 1411).

None sighted

No Evidence of quantitative noise monitoring against Standards.

Auditor concludes there is a lack of evidence for quantitative noise monitoring, hence the Audit Criteria cannot be assessed with confidence.

Improvement:

Review O&M EMP to consider applicability of Airborne Noise Standard

Undetermined (due to lack of Evidence)

3. Waste management Evidence Audit Findings and Comments Compliance

a. All EGSC works crew

contractors engaged to have

independent waste

management arrangements

to include waste

minimization, containment,

segregation and appropriate

reuse, recycling, treatment

and disposal.


Photographs

Auditor’s visual observations

EGSC Weekly Inspection Logs record maintenance activities relating to waste, bins and toilets.

On-site bins observed by Auditor.

Toilet cleaning contractor engaged to maintain toilets.

No indication or suggestion that waste is not being managed appropriately.

However no evidence provided to demonstrate that “contractors engaged … have independent waste management arrangements ……”

Auditor concludes the available evidence suggests waste is being managed appropriately and there has been no impact to environmental values, although no Contractor documentation exists, hence the Audit Criteria is not met and therefore is considered a Minor Non-Compliance.




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Improvement:

Require Contractors to develop and submit “waste management arrangements to include waste minimization, containment, segregation and appropriate reuse, recycling, treatment and disposal”.

b. All waste must be removed

from the site.


Photographs


EGSC Weekly Inspection Logs record occasional waste and bins maintenance activities.

EGSC staff advised Auditor that all waste removed from site. Photographs demonstrate site to be free of ‘waste’ from operations and maintenance activities.

No waste observed on site by Auditor.


Fully Compliant

c. The handling and disposal of

unexpected materials

identified during dredging/

excavation/maintenance (eg.

inert debris such as concrete

and timber) to be included in

waste management

arrangements.



Notes from interview with EGSC staff


No record of unexpected materials being encountered during operations and maintenance activities.


Fully Compliant

d. All waste bins must be

wildlife proof so as to

eliminate litter and access by

wildlife and/or encourage

vermin.


Photographs


Evidence suggests on-site waste bins (small) are fitted with lids.

No report of wind-blown litter. No report of injury to wildlife.


Fully Compliant

e. All waste to be managed in EGSC Weekly Inspection EGSC Weekly Inspection Logs record waste and bins maintenance activities. Minor



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accordance with:

Environment Protection Act 1970 (Vic)

Pollution of Waters by Oil and Noxious Substances Act 1986 (Vic)

Logs



Photographs

EGSC Catfish Dredge SWMS

Auditor observed oil spill response equipment on-board Catfish Dredge and at EGSC depot.

EGSC Works Supervisor advised Auditor that oil spill response equipment was stationed onsite for all works activities, and contractors carried additional oil spill response equipment. Photographs and email records demonstrate oil spill response equipment at ramp ready for deployment during dredging and excavation. Photographs illustrate oils spill kits on some contractor equipment.

Auditor has previously sighted KcKinnon Earth Construction’s procedures for oil spill and noxious substance discharge (Project Management Plan, Daily Logs, SWMS Checklist), however no evidence provided for 2018 year.

Minor hydraulic leak occurred as discussed under Criteria 20 below.

Auditor concludes oil spill response equipment is adequately stationed on-site and within (some) equipment, ready for deployment. However the available evidence suggests there is a lack of documented response procedures for oil spill and noxious substance discharge by all contractors using equipment / machinery near or over water (Appx 7 O&M EMP). Whilst there has been no resulting impact to the environment, the Audit Criteria is not met and hence is considered a Minor Non-Compliance.

Improvement:

Develop comprehensive response procedures / arrangements / systems (ie SOP’s SWMS etc), in co-operation with all staff and contractors, to ensure sufficient systems were in place to mitigate threat of an oil spill or noxious substance discharge during operation of any machinery near or over water (eg dredge, excavators, front end loaders).

Non-Compliance

4. Equipment maintenance Evidence Audit Findings and Comments Compliance

a. Maintenance programs will

be implemented for all plant

and equipment as defined in


EGSC Bastion Pt Dredging

EGSC Weekly Inspection Logs mention equipment and machinery use. Dredging Operations Work Diary / Log Book mention Tool box meetings. EGSC Catfish Dredge pre-start check lists have been completed, however no




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EGSC procedures and the

Occupational Health and

Safety Regulations 2007

(Vic).

Operations Work Diary / Log Book


EGSC Catfish Dredge pre-start check list

KcKinnon Earth Constructions SWMS

record of machinery maintenance logs were provided.

Machinery inspection and maintenance logs were provided for EGSC truck and dredge trailer.

No records were sighted of machinery maintenance for Contractor’s equipment: excavation, diving inspections, ramp cleaning etc.

Available evidence suggests equipment maintenance records are documented for Council equipment, but no evidence exists for contractor plant and equipment. The Audit Criteria is not fully met and hence is considered a Minor Non-Compliance.

Improvement:

Develop data capture and record keeping protocol to demonstrate maintenance of all Contractor’s plant and equipment.

5. Fuels, oils, chemicals

and hazardous goods Evidence Audit Findings and Comments Compliance

a. Storage and handling of

chemicals in accordance

with:

Dangerous Goods Act 1985 (Vic)

Pollution of Waters by Oil and Noxious Substances Act 1986 (Vic)



Ecoterra Oil Safety Data Sheet



Auditor observed oil spill response equipment on-board Catfish Dredge and at EGSC depot.

EGSC Works Supervisor advised Auditor that no oil, fuel, noxious substances or dangerous goods were stored onsite at MOABR during normal operations in 2018 (ie. when no equipment is used onsite), nor when machinery was onsite for maintenance works, and that no equipment re-fuelling occurred on-site.

EGSC Works Supervisor has successfully implemented use of ‘eco-friendly’ Ecoterra Oil in operations and maintenance of all Council machinery / equipment,

No records available of any oils, fuels, noxious substances or dangerous goods that were stored onsite by contractors at MOABR.

Auditor did not sight any SOPs or SWMS for ‘Working Near or Over Water’ (Appx 7 O&M EMP) completed by contractors.

Auditor concludes there is a lack of documentation relating to storage and




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handling of fuels, oils, chemicals and hazardous goods for machinery used on-site, but that there was no resulting impact to the environment, and hence the Audit Criteria is not fully met and is therefore considered a Minor Non-Compliance.

Improvement:

Modify EGSC Weekly Inspection Logs and EGSC Bastion Pt Dredging Operations Work Diary / Log Book to include inspection for all on-site hazardous materials (including confirmation that none is on-site). Create Hazardous Substances Register and establish system for documenting and retaining records of all hazardous materials used by contractors .

6. Emergency response

preparedness Evidence Audit Findings and Comments Compliance

a. Development and testing of

emergency response

procedures, integrated with

the EMP, including provision

for fuel, oil and chemical

spills.



WorkSafe Victoria Incident Report Ref: V01002003700L

EGSC Man Overboard (MOB) procedure




Photographs

EGSC Works Supervisor advised Auditor that EGSC staff previously completed Oil Spill Response Training in 2017. However no records or documented evidence of staff training was sighted by the Auditor. No evidence sighted of Oil Spill Response Training being completed in 2018.

Dredging Operations Work Diary / Log Book and Weekly Inspection Logs document an unannounced visit to site by WorkSafe Victoria during dredging operations (March 28

th, 2018), resulting in a Notice to Comply in relation to lack of

Man Overboard (MOB) procedure. Ref: V01002003700L. EGSC subsequently developed MOB to WorkSafe Victoria’s satisfaction. Auditor has sighted EGSC’s MOB procedure. WorkSafe Victoria revisited site in June. No incidents reported.

Auditor previously sighted KcKinnon Earth Constructions SWMS for 2017, however not sighted for 2018.

EGSC Catfish Dredge SWMS includes procedural arrangements and risk assessment, including Sign-on & Close-out record, and minor emergency response elements.

Auditor observed oil spill response equipment on-board Catfish Dredge and at EGSC depot available for deployment.




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No evidence of Register of Emergency Response Tests (App 8 of O&M EMP) being completed.

No evidence of Emergency Test and Incident Review Form (App 10 of O&M EMP) being completed.

No evidence of Emergency Response Test by contractors.

Auditor concludes emergency response procedures were not adequately developed or tested, including for contractor activities, but that no record exists of an emergency incident seriously affecting the environment, and hence represents a Minor Non-Compliance.

Improvement:

Develop and test emergency response procedure (including for all contractors), and retain records in accordance with App 8 & 10 of O&M EMP.

b. All dredging vessels /

excavation to have oil spill

response kits. Relevant

personnel to be trained in its

use.




Photographs

Auditor observed oil spill response equipment on-board Catfish Dredge and at EGSC depot available for deployment.

EGSC Works Supervisor advised Auditor that EGSC staff previously completed Oil Spill Response Training in 2017. However no records or documented evidence of staff training was sighted by the Auditor. No evidence sighted of Oil Spill Response Training being completed in 2018.

EGSC staff advised Auditor that oil spill response equipment was stationed onsite for all works activities, and contractors carried additional oil spill response equipment. Photographs and email records demonstrate oil spill response equipment at ramp ready for deployment during dredging and excavation. Photographs illustrate oils spill kits on some contractor equipment.

Auditor concludes oil spill response kits were available onsite and limited staff training occurred, however no documented evidence exists. The Audit Criteria is considered Compliant but Requires Improvement.

Improvement:

Compliant but Requires Improvement



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Document staff oil spill response training.

Document existence of oil spill response kits on all contractor’s plant and equipment.

c. Gippsland Region Marine

Pollution Contingency Plan is

amended to reflect projected

increased activity following

construction

Gippsland Region Marine Pollution Contingency Plan

Online copy of Marine Pollution Contingency Plan highlights risk of increased marine pollution event occurring at Bastion Point boat ramp.


Fully Compliant

Table 5: MARINE-BASED WORKS

Objective:

To appropriately manage marine-based works.

To minimise disturbance to and appropriately manage non-Aboriginal heritage.

To minimise impacts on cetaceans.

To mitigate the impact of oil spills or other marine pollution events.

Application:

All marine-based MOA activities.

Target:

Conformance with all environmental limits and controls.

7. Marine pests –

If Dredging / Excavation

equipment is mobilized

Evidence Audit Findings and Comments Compliance

a. Marine pest inspection and

certification of contract

dredge and support vessel is

required before mobilization,


Auditors observations

Email correspondence

Not applicable as there were no contracted dredge and support vessels used during 2018 operations and maintenance activities that were sourced from outside of Mallacoota Inlet.

The Audit Standard / Criteria in O&M EMP is poorly worded with respect to

Not Applicable



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where these are sourced

from outside Mallacoota Inlet.

Certification must be

received from the final port of

call, before mobilization.

relating to draft audit findings

“sourced from waters outside of Mallacoota Inlet”, and phrasing suggests it is intended for larger vessels arriving at Mallacoota via sea transport.

Catfish Dredge was used on North Arm in the Gippsland Lakes, near lakes Entrance in November 2018, and was washed down at Abalone Co-operative prior to use at MOABR.

Improvement:

Reword O&M EMP Audit Standard / Criteria 7a to better reflect the dredge and support vessels being used at MOABR.

Develop procedures and data capture / record keeping protocols to minimise the threat of introducing marine pests from Catfish Dredge and support vessels being used in waters beyond Mallacoota, including a register of all necessary decontamination certification.

b. All vessels to comply with

Protocol for Environmental

Management – Domestic

Ballast Water Management in

Victorian State Waters, EPA

Publication 949.2 (April 2008)

NA

Not applicable as vessels requiring ballast water were not used during 2018 operations and maintenance activities.

Note: EPA Publication 949 has been updated.

Improvement:

Review O&M EMP Audit Standard / Criteria 7B to determine if applicable.

Update O&M EMP to reflect most current version of EPA Publication 949, if remains relevant.

Not Applicable

c. All vessels to comply with

Australian Ballast Water

Management Requirements,

AQIS (June 2007).

NA

Not applicable as vessels requiring ballast water were not used during 2018 operations and maintenance activities.

Note: Australian Ballast Water Management Requirements, DAFF has been updated.

Improvement:

Review O&M EMP Audit Standard / Criteria 7C to determine if applicable.

Update O&M EMP to reflect most current version of Australian Ballast Water

Not Applicable



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Management Requirements, if remains relevant.

d. Train staff undertaking

construction and

maintenance activities in

identification of marine pests,

and reporting procedure.

None sighted

Catfish Dredge was used on North Arm in the Gippsland Lakes, near lakes Entrance in November 2018. No certification or evidence sighted to indicate Catfish Dredge was cleaned to remove potential marine pests,

No evidence sighted to indicate staff were adequately trained to identify and report potential marine pests, particularly Northern Pacific Seastar.

Auditor concludes the audit criteria has not been fully met, however it is unknown if the environment has been seriously affected, hence is considered a Minor Non-Compliance.

Improvement:

Implement training to enable staff to identify and report potential marine pests, particularly when Catfish Dredge is used in waters beyond Mallacoota.


8. Vessel Refuelling Evidence Audit Findings and Comments Compliance

a. All refuelling to take place in

accordance with Marine

Safety Victoria’s guideline,

Port Management

Regulations, Gippsland

Ports’ Harbour Master

directions.





EGSC staff advised Auditor that No on-water refuelling of dredge or support vessels was necessary during 2018 operations and maintenance activities. And refuelling of all other maintenance (earthmoving) plant and equipment was undertaken off-site, away from MOABR (ie. at depot).

Oil and fuel spill kits kept were stationed onsite during maintenance activities.


Fully Compliant

9. Cetaceans – vessel

manoeuvring Evidence Audit Findings and Comments Compliance

a. If within 300m of a dolphin or

whale the vessel must not:

EGSC Bastion Pt Dredging Operations Work Diary /

EGSC staff advised Auditor that dolphin sightings occurred on several occasions Compliant but Requires



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Approach a whale or

dolphin head on; or

Be in the path of a

whale or dolphin; or

Separate any whale or

dolphin from a group; or

Come between a

mother and a calf; or

Drop or lower an

anchor overboard from

the vessel.

b. Within 300m of a whale or

dolphin, the vessel must:

Maintain a constant

speed that does not

exceed 5 knots; and

Avoid sudden changes

in direction; and

Maneuver the vessel to

a distance of at least

200m from the whale or

dolphin if it shows any

sign of disturbance,

when safe to do so.

Log Book


during 2018 maintenance activities involving EGSC Catfish dredge.

Auditor believes (based on verbal comment) that there may be confusion regarding the distance Cetaceans may approach before ceasing works.

Dredging Operations Work Diary / Log Book and Weekly Inspection Logs record if Dolphins have been sighted and if dredging works were halted (ie 150 metres verses 300 metres).

No operational procedure exists for response to Cetaceans sightings during operation of dredge and support vessels.

Auditor concludes EGSC staff, dredge operators and contractors complied with Cetacean requirements but that no documented operational procedure exists for response to Cetaceans sightings. The available evidence demonstrates Compliance with the Audit Criteria but that Improvements are Required.

Improvement:

Develop and implement operational procedure for response to Cetacean sightings during operation of dredge and support vessels.

Improvement

10. Heritage (marine based) –

identification of potential

relics




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a. If potential relics are

identified during construction

activities, the process

described in Annexure 11

Response Process will be

followed.




EGSC staff advised Auditor that no heritage relic material was encountered during 2018 operations and maintenance activities.

Weekly Inspection Logs and Dredging Operations Work Diary / Log Book make no mention of heritage relic material being encountered.


Fully Compliant

Table 6: DREDGING / EXCAVATION and PLUME

Objective:

To appropriately manage dredging / excavation activities and sediments.

To minimize the area of channel and seabed disturbed and appropriately manage the material removed.

To protect assets, beneficial uses and values from long-term adverse effects to dredging-related water quality effects.

Application:

All relating to maintenance of navigation depth activities.

The disposal of dredged / excavated material.

Use of dredges / excavators and associated equipment.

Target:


11. Dredging / Excavation

and plume Evidence Audit Findings and Comments Compliance

a. Dredging and/or excavation

must remain within the

identified channel zones, and

will be confirmed by recorded

GPS data.

EGSC Weekly Inspection Logs, including annotated Crossco Drawing No. 1579/007-C

EGSC Bastion Pt Dredging Operations Work Diary /

EGSC Catfish dredge and various contractors (including KcKinnon Earth Constructions, Kina Diving, Environmental Marine Solutions) operated at MOABR in 2017 to remove sand shoals from the channel and ramp apron.

Annotations by EGSC Works Supervisor and staff on Crossco Drawing No. 1579/007-C delineate areas of shallow sand as a guide for dredging and




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Channel zones” are shown

on Crossco Drawing No.

1579/007-B included in

Appendix 12

Log Book, including annotated Crossco Drawing No. 1579/007-C




Photographs

excavation operations.

Excavation and removal of sand from the boat ramp aprons (using excavator, loader and truck) was required whenever shallow water depths prevented access by the Catfish dredge vessel.

GPS records and track logs of Catfish dredge vessel in channel or excavator in shallows were not captured by either EGSC staff or contractors.

No evidence was sighted by the Auditor to confirm spatial extent of dredging activities and excavation, except photographs depicting that shoals had successfully been removed.

Extent of dredged zone and excavation is most likely to have occurred within the designated area (on Crossco Drawing No. 1579/007-B) because rock outcrops generally prevents such activity outside the marked area.

Auditor concludes that GPS readings were not taken to delineate extent of dredged and excavation zone but that the environment is unlikely to have been seriously affected, hence represents a Minor Non-Compliance.

Improvement:

Develop and implement improved method for recording that all dredging and/or excavation activity remains within the identified channel zones.

Update O&E EMP to correctly identify that Crossco Drawing No. 1579/007-B has been updated to 1579/007-C.

b. Recording of equipment

activity on log sheets will

include the following

information as a minimum:

Dredge/Excavator:

Management of sand from

….., and

EGSC Weekly Inspection Logs, including annotated Crossco Drawing No. 1579/007-C

EGSC Bastion Pt Dredging Operations Work Diary / Log Book, including annotated Crossco Drawing No. 1579/007-C

Designated dredge/excavation and disposal sites are annotated on Crossco Drawing No. 1579/007-C.

Auditor’s previous observations and photographs illustrate dredged sand being discharged via pipeline, or relocated by excavator, to the designated site.

Photographs show rocks and pebbles deposited within designated disposal site, which were subsequently removed from beach by machinery.

Dredge records are documented in the newly developed Bastion Pt Dredging




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Sailing and placement of

sand to …..

Other Equipment

Management of sand from

….

Reason for use of equipment


Photographs

Operations Work Diary / Log Book. No contractor machinery logs were sighted.

The Auditor did not sight any log sheets set out in the prescribed format.

Auditor believes prescribed format relates better to offshore hopper dredging rather cutter dredge with disposal pipeline, such as EGSC Catfish dredge.

Auditor concludes performance standard has not been achieved but that environment was unlikely to have been seriously affected, hence represents a Minor Non-Compliance.

Improvement:

Review O&M EMP Audit Standard / Criteria 11B to better reflect equipment being used at MOABR.

Develop and implement improved method for recording that all dredging and/or excavation activity remains within the identified channel zones

Table 7: CHANNEL MAINTENANCE SCHEDULE

Objective:

To develop an appropriate maintenance schedule, taking into account the seasonal sensitivities of the Mallacoota Inlet assets,

beneficial uses and values.

Application:

All channel Maintenance activities.

Target:


12. Dredging / excavator

schedule Evidence Audit Findings and Comments Compliance

a. Dredging / excavation to take

place in accordance with

construction plans showing

EGSC Weekly Inspection Logs, including annotated Crossco Drawing No.

EGSC Catfish dredge and various contractors (including KcKinnon Earth Constructions, Kina Diving, Environmental Marine Solutions) operated at MOABR in 2018 to remove sand shoals from the channel and ramp apron.

Fully Compliant



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channel location and depths 1579/007-C

EGSC Bastion Pt Dredging Operations Work Diary / Log Book, including annotated Crossco Drawing No. 1579/007-C

Photographs

Notice to Mariners issued by Gippsland Ports

EGSC emails regarding operations and maintenance activities

EGSC Traffic Management Plan

Operational aspects of MOABR recorded on Weekly Inspection Logs and in Dredging Operations Work Diary / Log Book.

Logs and annotations by EGSC staff on Crossco Drawing No. 1579/007-C delineate areas of shallow sand

Excavation and removal of sand from the boat ramp aprons was required whenever shallow water depths prevented access by the Catfish dredge vessel, and was recorded on Weekly and Monthly Inspection Logs.

Monthly Inspection Log includes prompt for channel depth measurement. Drawing No. 1579/007-C includes table for recording channel depths. However depths were not measured or recorded in 2018.

Slippery condition of concrete ramp apron and cleaning requirement recorded on Weekly Inspection Logs.

Navigation Warning signs erected and checked by EGSC.

Traffic Management Plan (including pedestrian traffic) were prepared and implemented during all dredging maintenance activities.

Notice to Mariners were issued by Gippsland Ports to address changing conditions of ramps and ramp closures during dredging operations.


13. Consideration of

seasonal sensitivities Evidence Audit Findings and Comments Compliance

a. Dredging /excavation

activities planned with a

particular awareness and

regard for high recreational

use periods (Easter, Summer



Photographs

2018 operations and maintenance activities involved dredging with EGSC Catfish dredge, sand excavation from shallow ramp aprons by contractors, and cleaning of ramp aprons by contractors.

EGSC Works staff advised Auditor all works were timed to avoid peak tourist periods wherever possible, but was subject to weather conditions and availability

Fully Compliant



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holidays, long weekends) EGSC emails and photos

EGSC traffic management plan

Public notices regarding maintenance works

Notice to Mariners

of contractors.

Traffic management plan implemented to manage vessel and pedestrian access.

Impact to ramp users was minimised by continuing to allow, under controlled/supervised conditions, the launch and retrieval of vessels during dredging activities.

Restricted pedestrians access resulted in several instances where members of the public became aggravated and abusive towards Council staff.


Table 8: DREDGED / EXCAVATED MATERIAL MANAGEMENT

Objective:

To manage and track the placement of removed material.

To relocate removed material and manage appropriately within approved near-shore locations.

Application:

All dredged / excavated and removed material placement.

Target:


14. Dredged / excavated

material placement Evidence Audit Findings and Comments Compliance

a. All dredged / excavated sand

placement to be placed:

within 300m of the “channel

zone” shown on Crossco

Drawing No. 1579/007-B

(included in Appendix 12);



Annotated Crossco Drawing No. 1579/007-C

Designated dredge/excavation and disposal sites are annotated on Crossco Drawing No. 1579/007-C.

Auditor’s observations and numerous photographs illustrate dredged sand being discharged via pipeline, or relocated by excavator, to the designated site.

Rocks and pebbles deposited within designated disposal site following excavation of shallow ramp aprons were removed by machinery to maintain beach for

Fully Compliant



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and

to the west of the

breakwater; and

above the low water mark

in the intertidal zone.


Photographs

EGSC emails and photos

Auditor’s observations

swimming purposes.

No dredging records, machinery logs or GPS data exists to document where piped and excavated material was placed (refer to Criteria 11 above).

Available evidence indicates all dredged and excavated material was placed in accordance with Crossco Drawing No. 1579/007-C and O&M EMP specifications.


b. Kelp removed from the ramp

and/or channel will be

disposed of in accordance

with EPA requirements.



Photographs

Kelp build-up within channel and on ramp is recorded on Weekly and Monthly Inspection Logs.

Auditor sighted no records of Kelp being physically removed.

EPA requirements for Kelp disposal do not exist.

Auditor concludes there is a lack of available evidence relating to removal and disposal of Kelp, and EPA requirements, hence the Audit Criteria cannot be assessed with confidence.


15. Disposal site monitoring Evidence Audit Findings and Comments Compliance

a. Site inspections will be

recorded and photographs

taken to provide evidence of

appropriate management.

The results of inspections will

be included in performance

reporting.



Annotated Crossco Drawing No. 1579/007-C


Photographs

EGSC emails regarding remobilisation of deposited

Refer to Criteria 11 and 14 above regarding disposal site management.

EGSC staff’s visual and photographic monitoring of dredged and excavated material disposal site indicates that deposited material is being washed out of disposal site by waves and tidal action, in southwards direction back onto boat ramp apron and back into launching channel, thereby circumventing dredging / excavation efforts.

Council has commenced process to seek DELWP Coastal Management Act Consent approval to implement remedial actions, which may include:

Installation of a geo-textile groyne as a physical barrier to prevent

‘circular sand flow’, and/or

Compliant but Requires Improvement



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dredge/excavated sand

relocate the approved disposal site, possibly to south of the breakwater.

Any remedial actions will require detailed geomorphological investigations to gain DELWP approval.

Auditor notes that no Performance Report was prepared as required by this Standard / Criteria.

Auditor concludes the available evidence adequately demonstrates Compliance with the Audit Criteria but that improvements are required.

Improvement:

Continue liaison with DELWP to investigate options and gain Coastal Management Act Consent approval for improvements to dredge / excavated material disposal site management. Objective should be to prevent ‘circular flow’ resulting in deposited material being washed southwards back onto boat ramp apron and back into launching channel.

Prepare a Performance Report to DELWP on management of disposal site, including options for prevention of ‘circular sand flow’ and deposition of rocks resulting excavation of shallow areas inaccessible by dredge.

Table 9: LAND BASED

Objective:

To manage operations and maintenance activities.

Application:

All land based works.

Target:


Conformance with approved Cultural Heritage Management Plan (CHMP).

16. Excavation, placement

and stockpiling of




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material

a. All Maintenance works to be

completed in accordance

with the approved:

Cultural Heritage

Management Plan

(CHMP);

Construction drawings

and specifications.



Photographs

Auditor’s onsite observations

Cultural Heritage Management Plan

Cultural Heritage Management Plan details requirements for avoidance and management of aboriginal cultural sites during construction period. Less emphasis is placed on operational and maintenance phase.

2018 operations and maintenance activities involved both dredging and excavation.

EGSC staff advised that known sites of Cultural Significance were not disturbed during 2018 operations and maintenance activities, which is supported by Auditor’s on-site observations.


Fully Compliant

17. Removal and

management of native

vegetation


a. All temporary site facilities

and vehicle management to

be within defined areas

approved by EGSC



Available evidence indicates that 2018 operations and maintenance activities were undertaken by staff and contractors as instructed by EGSC Works Supervisor. All activities were undertaken within the approved MOABR area as defined in the O&M EMP. No additional designated area was defined by EGSC.


Fully Compliant

b. All operations and

maintenance to be completed

in accordance with each as

may be amended from time-

to-time: Coastal Management



Notes from interview with

Available evidence indicates that 2018 operations and maintenance activities were undertaken within the approved MOABR area as defined in the O&M EMP, the Coastal Management Act Consent.

Permit issued by Gippsland Ports for maintenance dredging and excavation activities.

Fully Compliant



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Act consent dated

14/01/2013, Crown Lease

conditions, and DEPI Native

Vegetation removal approval

dated 4 September 2011

EGSC staff


Photographs

Gippsland Ports Permit

Available evidence indicates 2018 operations and maintenance activities resulted no additional vegetation removal.


18. Weeds and pest animals Evidence Audit Findings and Comments Compliance

a. Domestic animals must be on

a lead at all times in

accordance with East

Gippsland Shire local law

requirements.




EGSC staff advised that no domestic animals (dogs) were on-site during operational and maintenance activities undertaken by Council staff or contractors.

Weekly Inspection Logs do not include checks for presence of domestic animals (dogs) on leads, but allow for such comments under “Other Observations”.

No other records sighted containing information regarding presence of domestic animals during 2018 operations and maintenance activities.

Auditor considers ‘Dogs on Leads’ to be a By-Law issue rather than an operational issue for MOABR.

Auditor concludes that based on EGSC staff advice (rather than documented evidence), the Audit Criteria is Fully Compliant.

Improvement:

Review O&M EMP to consider appropriateness of Criteria 18a within O&M EMP rather than managed thorough corresponding By-Laws

Fully Compliant

a. No topsoil will be imported to

the site




Weekly Inspection Logs and the Dredging Operations Work Diary / Log Book do not include checks for importation of topsoil.

No other records sighted regarding topsoil importation restrictions during 2017 operations and maintenance activities.

Auditor considers “Imported Soil” Criteria within O&M EMP may have been more appropriate during construction phase of MOABR.




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Auditor concludes there is a lack of evidence indicating checks restricting importation of topsoil were undertaken, hence the Audit Criteria cannot be assessed with confidence.

Improvement:

Review O&M EMP to consider appropriateness of “Imported Soil” Criteria within O&M EMP.

Alternatively, include checks for imported soil and “weed free” status in the Bastion Pt Dredging Operations Work Diary / Log Book.

b. All material imported to the

site will be free of seed stock,

unless specifically approved

EGSC




No other records sighted regarding topsoil importation restrictions during 2017 operations and maintenance activities.

There is no evidence that EGSC issued approval for importation of seed stock.

Auditor considers “Imported Soil” Criteria within O&M EMP may have been more appropriate during construction phase of MOABR.

Auditor concludes there is a lack of evidence indicating checks restricting importation of seed stock were undertaken, hence the Audit Criteria cannot be assessed with confidence.

Improvement:

Review O&M EMP to consider appropriateness of “Imported Soil” Criteria within O&M EMP.

Alternatively, include checks for imported soil and “weed free” status in the Bastion Pt Dredging Operations Work Diary / Log Book.


19. Sediment transport

control Evidence Audit Findings and Comments Compliance

a. No contaminated stormwater

to leave the construction site.


EGSC Bastion Pt Dredging

Weekly Inspection Logs and Dredging Operations Work Diary / Log Book do not include checks for stormwater management.

Fully Compliant



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Operations Work Diary / Log Book


Photographs

No operations and maintenance activities undertaken in 2018 were likely to generate contamination other than oil or fuel spills form car park area or ramp apron. Oil and fuel spills are addressed in Criteria 5 and 8 above.


b. Where vegetation cover is

inadequate to protect soil, silt

traps must be constructed

and maintained and form part

of regular inspections





Photographs

Weekly Inspection Logs do not include checks for vegetation cover or soil erosion.

Photographs and Auditor’s observations suggest areas disturbed during construction of MOABR have now fully rehabilitated and no soil or silt traps are required.


Fully Compliant

Table 3: EXTERNAL NOTIFICATION and REPORTING REQUIREMENTS – OPERATIONS and MAINTENANCE PHASE

Objective:

To report performance against EMP to Government agencies and stakeholder groups

Application:

None listed

Target:

None identified

20. Reporting Requirement Evidence Audit Findings and Comments Compliance

Pollution event or imminent environmental hazard (as defined in Environmental Auditor

Copy of relevant report



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Guidelines for Conducting Environmental Audits, Publication 953.2, October 2007, EPA, Victoria)

EPA, DEPI, GP, TSV

Notification within 4 hours.

Incident report required.

Notification to GP as soon as

practicable.




EGSC emails

EGSC Photographs

Notice to Mariners

Weekly Inspection Logs and Dredging Operations Work Diary / Log Book record minor hydraulic oil leak on CatFish Dredge while operating over water. EGSC OH&S Incident Report form completed and provides additional details.

Approximately 5 litres of oil leaked, of which approximately 4 litres was captured. Approximately 1 litre spilled into ocean. Dredging operations were halted and dredge removed back to depot.

EPA were notified (Ref: 200165921). No further action taken by EPA.

Risk / Event Report Form (Appx 9 of O&M EMP) not completed.

No notification to DELWP.

Lack of ‘interest’ by EPA may have incorrectly suggested to EGSC that no further reporting was required.

Auditor concludes a Non-Compliance has occurred in terms of failure to fully document minor operational incident and failure to notify government agency (DELWP), but that there are no direct environmental implications, hence a Minor Non-Compliance.


Project Delivery Standard Evidence Audit Findings and Comments Compliance

DEPI

Notification within one

business day of verifying

non-conformance with a

PDS.




Environmental Incident reports

No Evidence of Environmental Non-Conformance report forms (Appx 13 in O&M EMP) being completed for minor operational incidents described immediately above.

No evidence that non-conformances relating to minor Oil spill and Works Safe Man Overboard notice (refer to Audit Criteria 20 and 6 above) were reported to DELWP.

Auditor concludes a Non-Compliance has occurred in terms of notifying DELWP of minor operational incident, but that there are no direct environmental implications,




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hence a Minor Non-Compliance.

Operational and Maintenance Activities


DEPI

Notification within 14 days of

commencement and

completion.

NA

Audit Criteria is ambiguous.

Auditor is uncertain if Audit Criteria requirement relates to notification of all Operational and Maintenance Activities at MOABR, or only those not authorised by existing approvals (eg CMA Consent).

Auditor is unable to determine compliance with Audit Criteria.

Improvement:

Amend O&M EMP to clarify intent of DELWP ‘Notification’ Audit Criteria.

Undetermined

(due to poorly defined Audit Criteria)



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