Contingency plan for emergency environmental incidents

Transcription

1 Draft envirnmental management plan Cntingency plan fr emergency envirnmental incidents Y-D Enter G back t cntents

2 Sants GLNG Upstream Cntingency Plan fr Emergency Envirnmental Incidents

3 Table f Cntents 1.0 Intrductin Purpse and Scpe Purpse Scpe Rles and Respnsibilities Legal and Other Requirements State Legislatin and Strategies Lcal Gvernment Plans Sants Envirnment, Health and Safety Management System Emergency Envirnmental Incidents in the Sants GLNG Upstream Prject Area Emergency Preparedness Framewrk Emergency Incident Organisatin Structure Emergency Respnse Plans and Prcedures Emergency Respnse Prcedures Emergency Respnse Actins General Respnse t an Emergency Envirnmental Incident General Respnse Measures Resurces fr Respnse Actins Key Cntact Lists Respnse and Management Teams Emergency Preparedness Plans Emergency Equipment Training Envirnmental Mnitring Cmmunicatin Internal Ntificatins Regulatry Ntificatins and Reprting Stakehlder Ntificatins Envirnmental Recvery Site Assessments Remediatin and Rehabilitatin f Cntaminated Land Incident Investigatin Evaluatin and Review Evaluatin Review Page i

4 8.0 Definitins References Tables Table 1: Summary f Key Applicable State Legislatin... 5 Table 2: Incident Assessment Matrix (EHSMS 13)... 7 Table 3: Methds t Assess Legal and Prcedural Effectiveness Figures Figure 1: The Sants GLNG Upstream Prject Area... 3 Figure 2: The Sants Apprach t Envirnmental Management... 6 Figure 3: Emergency Preparedness Management Organisatin Structure... 8 Figure 4: Sants Incident Escalatin Prcess (EHSMS 13)... 9 Figure 5: Structure f Sants GLNG Emergency Preparedness Management System Page ii

5 Abbreviatins and Units Acrnym AS CMP CMT DEHP EA ECP EHS EHSMS EOC Descriptin Australian Standard Crisis Management Plan Crisis Management Team Department f Envirnment and Heritage Prtectin Envirnmental Authrity Cntingency Plan fr Emergency Envirnmental Incidents Envirnment, Health and Safety Envirnment, Health and Safety Management System Emergency Operatins Centre EP Act Envirnmental Prtectin Act 1994 EP Regulatin Envirnmental Prtectin Regulatin 2008 ERP ERT FRT GED GLNG IMP IMS IMT IOC NZS QIMP SCMP Emergency Respnse Plan Emergency Respnse Team Field Respnse Team General Envirnmental Duty Gladstne Liquefied Natural Gas Incident Management Plan Incident Management System Incident Management Team Incident Operatins Centre Standards New Zealand Queensland Incident Management Plan Sants Crisis Management Plan SDPWO Act State Develpment and Public Wrks Organisatin Act 1971 SDS Safety Data Sheet Page iii

6 1.0 Intrductin Unauthrised and unfreseen releases f hazardus and/r plluting substances can present an immediate and unacceptable shrt-term r lng-term threat t the envirnment and persns. Similarly, a natural event that arises external t cnstructin r peratinal activities can present immediate and unacceptable shrt-term r lng-term threats t assets (including envirnmental assets) and persns. Dependent n the risks t envirnmental values r prximity t sensitive receptrs, such releases require timely r immediate actin emergency actin fr crdinating and implementing cuntermeasures t prtect the envirnment, persns and assets frm adverse effects and fr ntifying apprpriate stakehlders and authrities. This Cntingency Plan fr Emergency Envirnmental Incidents (herein referred t as the ECP) aims t prvide an verview f management practices in place within Sants GLNG t minimise envirnmental harm during emergency envirnmental incidents. This ECP identifies ptential emergency envirnmental incidents and details f a respnse t an emergency envirnmental incident, including escalatin, cmmunicatin, reprting and mnitring. 1.1 Purpse and Scpe Purpse This ECP has been prepared t satisfy the requirements f the relevant Sants GLNG Upstream Prject Area Envirnmental Authrities (EAs) and C-rdinatr General s Evaluatin Reprt. This plan cmplements the verarching Sants Envirnment, Health and Safety Management System (EHSMS). The bjectives f this ECP are t: Facilitate cmpliance with relevant State and lcal Gvernment legislatin, regulatins and apprvals; Supprt the Sants Envirnmental, Health and Safety Management Standard EHSMS 13 - Emergency Preparedness and EHSMS 15 - Incident Investigatin and Respnse; Prvide a framewrk fr Sants GLNG t: Prepare fr and respnd t emergency envirnmental incidents; Cmmunicate with the apprpriate parties in the event f emergency envirnmental incidents; Investigate the cause f emergency envirnmental incidents that have ccurred; Implement remedial actins t reduce the likelihd f recurrence f similar emergency envirnmental incidents; and Develp prcedures and plans fr the management f emergency envirnmental incidents as required during the Prject lifetime Scpe The ECP prvides an verview f Sants GLNG emergency preparedness management and respnse strategy, methds and cntrls fr emergency envirnmental incidents. Specifically, this ECP: Identifies ptential emergency envirnmental incidents within the Sants GLNG Upstream Prject Area; and Describes the emergency preparedness framewrk including general measures t manage and mitigate pssible scenaris invlving emergency envirnmental incidents. Page 1

7 The ECP des nt address Sants GLNG s respnse framewrk t incidents that are nt deemed t be an emergency r t hazards that may present an emergency if nt apprpriately managed. Refer t the Sants EHSMS 15 Incident Investigatin and Respnse and supprting dcumentatin fr the management and respnse t incidents nt deemed an emergency. The ECP is t be implemented by all Sants GLNG persnnel thrughut the explratin, cnstructin, prductin, decmmissining and rehabilitatin phases f the Prject. The ECP applies t activities carried ut within the Sants GLNG Upstream Prject Area. The Sants GLNG Upstream Prject Area cnsists f Sants GLNG petrleum tenements cmprising the Arcadia, Fairview, Rma And Sctia gas fields and as illustrated in Figure 1. Page 2

8 Figure 1: The Sants GLNG Upstream Prject Area Page 3

9 2.0 Rles and Respnsibilities Sants GLNG Prject persnnel are respnsible fr the envirnmental perfrmance f their activities, fr cmplying with relevant apprval / permit requirements and fr ensuring that all envirnmental bjectives assciated with the wrk are achieved. Sants GLNG Prject persnnel must als be mindful f the General Envirnmental Duty (GED) as utlined in the Envirnmental Prtectin Act 1994 (Qld) (EP Act). Sectin 319(1) f the EP Act states that a persn must nt carry ut any activity that causes, r is likely t cause, envirnmental harm unless the persn takes all reasnable and practical measures t prevent r minimise the harm. Rles, respnsibilities and accuntability under the ECP will be assigned in accrdance with the Sants EHSMS05 Respnsibility and Accuntability. Page 4

10 3.0 Legal and Other Requirements Applicable legislatin, regulatins, guidance and strategies enacted by the State f Queensland and lcal gvernments regarding emergency envirnmental incidents in the Sants GLNG Upstream Prject Area are described in the fllwing sectins. 3.1 State Legislatin and Strategies An verview f Queensland legislatin and strategies cnsidered in the develpment f the ECP are presented in Table 1 belw. Table 1: Summary f Key Applicable State Legislatin Act / Regulatin / Plicy State Develpment and Public Wrks Organisatin Act 1971 (SDPWO Act) Envirnmental Prtectin Act 1994 (EP Act) Envirnmental Prtectin Regulatin 2008 (EP Reg) Disaster Management Act 2003 Summary f Act / Regulatin / Plicy The SDPWO Act draws tgether a range f pwers and functins used by the State Gvernment t facilitate the apprval f large prjects. It prvides a frmal envirnmental impact statement (EIS) prcess fr significant prjects. Determined as a significant prject under the SDPWO Act, the Crdinatr- General s evaluatin reprt fr the Sants GLNG Prject s EIS impses varius cnditins n the prject, including cnditins fr the develpment f cntingency plans and emergency prcedures. The bjective f the EP Act is t prtect Queensland s envirnment by prmting eclgically sustainable develpment. Sants GLNG hlds a series f EAs issued under the EP Act which authrises the develpment f the Sants GLNG Upstream Prject Area. These EAs include requirements fr an emergency envirnmental incidents cntingency plan. The EP Act als requires Sants GLNG t take all reasnable and practicable measures t prevent r minimise envirnmental harm. Under the Disaster Management Act 2003, each reginal cuncil is required t develp a Disaster Management Plan which facilitates the implementatin f effective and efficient disaster management strategies and arrangements specific t each regin (e.g. flding, bushfire etc.). 3.2 Lcal Gvernment Plans Each f the Lcal Gvernment Areas in which the Sants GLNG Upstream Prject Area lies, maintains a Disaster Management Plan. Each f the plans listed belw has been cnsidered in the develpment f this ECP and in the management f emergency envirnmental incidents within the respective cuncil bundaries: Marana Reginal Cuncil Lcal Disaster Management Plan, 2012; Central Highlands Reginal Cuncil Lcal Disaster Management Plan, 2012; Banana Shire Lcal Disaster Management Plan, 2012; Western Dwns Lcal Disaster Management Plan, Sants GLNG will maintain effective cmmunicatins with the Lcal Gvernment when crdinating any emergency respnse activities. Page 5

11 3.3 Sants Envirnment, Health and Safety Management System The Sants EHSMS, prvides a framewrk fr envirnmental and safety practices acrss Sants peratins wrldwide. The framewrk has been develped t be cnsistent with AS 4801:2000 Occupatinal Health and Safety Management Systems and AS/NZS ISO 14001:2004 Envirnmental Management Systems. The ECP has been develped t meet the requirements f the EHSMS by utilising the Sants Standard EHSMS 13 Emergency Preparedness and EHSMS 15 Incident Investigatin and Respnse. These standards define the minimum acceptable standards fr emergency preparedness and incident investigatin and respnse fr Sants peratins and activities. This ECP specifically addresses unique features and requirements relating t the Sants GLNG Prject. Sants GLNG specific dcumentatin is based n identified envirnmental and reputatinal risks and accunt fr Sants GLNG s legal and ther bligatins, cmmitments made by the Sants GLNG Prject and Sants GLNG s Scial Licence t Operate. In this cntext, the ECP prvides additinal guidance fr the management f envirnmental issues and supprts the develpment f asset / activity / department based guidelines and wrk instructins, in rder t secure cmpliance with legal requirements as well as deliver n cmpany envirnmental standards. The Sants apprach t envirnmental management is illustrated in Figure 2. Figure 2: The Sants Apprach t Envirnmental Management Page 6

12 4.0 Emergency Envirnmental Incidents in the Sants GLNG Upstream Prject Area An emergency envirnmental incident is a sudden and immediate threat t the well-being f the envirnment that calls fr immediate measures t minimise its adverse cnsequences. Within Sants GLNG, emergency envirnmental incidents are thse that have an incident severity f Categry 4 r Categry 5 n the Sants Incident Assessment Matrix (refer Table 2). Table 2: Incident Assessment Matrix (EHSMS 13) Whilst every incident will require an assessment against the Incident Assessment Matrix t determine if the event is an emergency, the fllwing are examples f ptential envirnmental emergencies relevant t activities undertaken in the Sants GLNG Upstream Prject Area: Natural disasters Flding; Bushfire; Sants GLNG activities Nn-rutine well stimulatin activities; Nn-rutine injectin activities; Lss f well integrity; Lss f pipeline integrity; Lss f hazardus dam integrity (i.e. vertpping r structural failure); Majr facility faults; Significant r uncntrlled release f hazardus chemicals and fuels. Page 7

13 5.0 Emergency Preparedness Framewrk 5.1 Emergency Incident Organisatin Structure Sants GLNG has a fur-tiered respnse structure fr managing incidents (including envirnmental incidents) the Field Respnse Team (FRT), the Emergency Respnse Team (ERT), the Incident Management Team (IMT) and the Crisis Management Team (CMT) as depicted in Figure 3. Figure 3: Emergency Preparedness Management Organisatin Structure Escalatin f emergency incidents thrugh the different respnse teams is t ccur in accrdance with the prcess shwn in Figure 4. Due t the perceived severity f an emergency envirnmental incident (i.e. in accrdance with Incident Assessment Matrix shwn in Table 2), as a minimum, the FRT, ERT and IMT will always be invlved in the respnse effrt. The CMT is required in respnse t a Level 5 incident. Page 8

14 Figure 4: Sants Incident Escalatin Prcess (EHSMS 13) Each f the teams shwn in Figure 3 is respnsible fr the implementatin f a relevant set f emergency preparedness plans, dependent n the incident type and severity and the asset invlved (refer Figure 5). The implementatin f the emergency preparedness plans will aid in minimising the ptential r actual envirnmental harm, in the event f an emergency envirnmental incident. Sants GLNG has develped a series f emergency preparedness plans as part f the Sants GLNG emergency preparedness management and respnse system. These plans are develped and maintained at three levels: Emergency Respnse Plan (ERP): a prcedural dcument maintained by site management utlining specific site / activity respnse expectatins fr emergency scenaris. Incident Management Plan (IMP): a tactical dcument maintained by Reginal / Business / Natinal level management utlining Department / Natinal respnse fr incidents, including management and peratinal supprt fr site / field based Emergency Respnse arrangements. Page 9

15 Crisis Management Plan (CMP): A strategic dcument managed by Crprate Security utlining crprate respnse t key scenaris with strategic implicatins fr Sants. Figure 5: Structure f Sants GLNG Emergency Preparedness Management System The emergency management and respnse plans must include the elements described in Sectin 5.2 in rder t meet the relevant requirements f this ECP and its assciated legislative requirements. The Sants GLNG Queensland Incident Management Plan is t be cnsulted fr further infrmatin regarding the functin and peratin f the emergency incident management teams. 5.2 Emergency Respnse Plans and Prcedures Sants GLNG emergency preparedness plans fr ptential emergency envirnmental incidents will be implemented. All plans include the fllwing minimum cntent: Clearly defined rles and respnsibilities f relevant emergency respnse persnnel thrugh Duty Cards; Emergency specific triggers based n the Sants Incident Escalatin Prcess (Figure 4); Emergency respnse prcedures; Resurces t be used in respnse t an emergency envirnmental incident; Availability f emergency respnse dcumentatin and prcedures; Relevant training; Emergency respnse and management teams; Emergency equipment; Mnitring (including prcedures fr accessing mnitring lcatins during emergency envirnmental incident); Cmmunicatin prcedures and crdinatin with stakehlders (e.g. emergency services, lcal gvernment and state gvernment); Ntificatins and reprting; and Page 10

16 Incident investigatin Emergency Respnse Prcedures Emergency respnse prcedures are prvided in the relevant emergency preparedness plans in the frm f Emergency Situatin Checklists. These Emergency Situatin Checklists are scenari based and act as a guide t assist the relevant emergency respnse persnnel when respnding t a specific emergency. Variatins t the checklists will be based upn sund emergency respnse management, engineering judgement and peratinal experience, and are at the discretin f the respnse leaders (e.g. the Duty Manager and On-Scene Cmmander). The emergency respnse and management teams will serve a critical rle in cntrlling an incident. The emergency respnse and management teams may meet regularly t review the emergency respnse prcedures and t update the prcedures as site cnditins warrant. Additinally, if imprvements in the respnse prcedures are identified, the ECP and ther relevant emergency preparedness plans will be updated accrdingly. Page 11

17 6.0 Emergency Respnse Actins 6.1 General Respnse t an Emergency Envirnmental Incident The general measures prvided in the sectins belw apply t all envirnmental incident scenaris. These measures will be executed in respnse t an envirnmental emergency t: Reduce the threat t human life r injury; Prtect against envirnmental damage; and Preserve infrastructure, prduct, and equipment. Mre specific respnse actins will be dependent n the type and lcatin f the emergency envirnmental incident and detailed in the relevant emergency preparedness and respnse plan General Respnse Measures 1. Evacuate (all nn-essential persnnel). 2. Eliminate (surces f ignitin, sparks, etc.). 3. Stp and Crdinate (stp surce f the incident (e.g. spill) and crdinate shut dwn f relevant equipment, if pssible). 4. Ntify (internal and external ntificatins); (a) All emergency envirnmental incidents must be reprted t the DM immediately upn discvery; and (b) Cnduct regulatry r emergency services reprt, as required. 5. Identify (material (if unknwn) and identify PPE, hazards, and respnse prcedures using SDSs). 6. Cntain / Islate (cntain released material / incident using emergency respnse equipment and/r set up perimeter t islate area). 7. Stabilise and Neutralise (neutralise / stabilise spilt material (where relevant), use absrbents t stabilise ther released materials etc). 8. Clean up (remve released materials, spill respnse materials, any affected media etc.) 9. Evaluate 10. Dcument 11. Investigate and Remediate (if necessary) Once the situatin has stabilised, refer t the fllwing sectins fr additinal infrmatin: Sectin 6.3 Envirnmental Mnitring: crdinate and implement the apprpriate mnitring regimen, determined n a case-by-case basis; Sectin 6.4 Cmmunicatin: ensure that the prper ntificatins are made. 6.2 Resurces fr Respnse Actins Key Cntact Lists The QIMP prvides a current Sants GLNG Duty Manager Rster and a cntact list f all the relevant emergency respnse persnnel in the Sants GLNG Prject. Frequently updated, this cntact list and the Sants GLNG Duty Manager Rster are made readily available t all Sants GLNG Prject persnnel n the Sants Intranet. Page 12

18 6.2.2 Respnse and Management Teams Emergency respnse and management teams (as illustrated in Figure 3) are resurced t respnd t the varius categries f emergency incidents and are activated thrugh the Sants Incident Escalatin Prcess (Figure 4). The rles and respnsibilities f these teams are utlined in Sectin 2.0 and mre specifically, are prvided in relevant emergency preparedness plans Emergency Preparedness Plans Emergency preparedness plans are readily available t Sants GLNG Prject persnnel attending emergency envirnmental incidents Emergency Equipment As specified in the EHSMS 13 Emergency Preparedness, a risk management prcess will be used t determine the type, quantity and lcatin f emergency equipment required fr an peratinal site. The asset Significant Hazard Risk Register will be used t assist with the determinatin f emergency equipment. Necessary emergency respnse equipment as determined frm the risk assessment f individual sites will be available t respnd t emergency envirnmental incidents. All emergency equipment lcated at the Emergency and/r Incident Operatins Centre (EOC and IOC) and at individual assets (permanent equipment fr immediate respnse t emergencies (e.g. fire extinguishers)) shall, as applicable: Be installed in accrdance with manufacturer s instructins and/r relevant Australian Standards r equivalent; Be readily accessible and within a reasnable distance frm the surce f the hazards; and Have apprpriate signage and lighting. The emergency equipment inventry shall be regularly inspected, tested and maintained in accrdance with relevant legislative requirements, standards and/r manufacturer s instructins. Relevant persnnel will be trained and cmpetent t use emergency equipment. Inspectins shall be carried ut by cmpetent persnnel in accrdance with cntrlled inspectin checklists Training Persnnel shall be trained in accrdance with the Sants Cmpetency Based Training Prgram t effectively fulfil their rles and respnsibilities in the Sants GLNG emergency preparedness management and respnse system. Training persnnel and exercising the IMP and ther emergency preparedness plans may be in the frm f simulated emergencies, practical drills, desktp exercises, resurces and equipment checks r ther exercises designed t systematically include all persnnel likely t be invlved. Emergency exercises shall be cnducted t: Test the effectiveness f the IMP and ther emergency preparedness plans; Validate the cmpetency f key emergency respnse persnnel; Assess the capability t respnd t an emergency; Reinfrce prir training; and Identify pprtunities fr imprvement. Page 13

19 6.3 Envirnmental Mnitring Envirnmental mnitring will be cnducted in respnse t an emergency envirnmental incident. The specific aspects f the envirnmental mnitring activities, including suitable mnitring lcatins, will vary depending n the nature f the incident and will be determined at the time f the incident. Typical mnitring that will be required may include: Visual and lfactry inspectins t determine the nature and extent f impacts and nging respnse actins; Vapur mnitring assciated with the release f gases and petrleum hydrcarbn and/r chemical vapurs t atmsphere; Field measurements f ph and cnductivity in released waters, waters cntained within temprary cntainment structures r tanks and receiving waters; and/r Labratry measurements t identify cnstituents f cncern in affected media where required (e.g., waters, sils). Mre rbust sampling and analysis will be cnducted in the pst incident investigatin, assessment and, if required, remediatin activities. This will include the implementatin f receiving envirnment mnitring prgrams where cntaminants have been released t land r water, s as t determine the extent f any envirnmental impact. Prgrams will include upstream, dwnstream and impact site mnitring fr releases t waters and a detailed sil mnitring prgram fr releases t land. 6.4 Cmmunicatin Internal Ntificatins Emergency incidents are ntified internally via the escalatin prcess illustrated in Figure 4. All emergency envirnmental incidents that are classified r has the ptential t be classified as Crisis (i.e. Categry 5), the relevant General Manager and Vice President shall be ntified immediately. They shall then liaise as necessary with the Safety and Envirnment Manager, Sants GLNG Legal Department, Senir Management and the Bard. Further, all emergency envirnmental incidents shall be recrded in the Incident Management System (IMS) as sn as pssible and in accrdance with requirements in EHSMS 15 Incident Investigatin and Respnse Regulatry Ntificatins and Reprting Ntificatins t regulatry bdies will be made in accrdance with the Sants GLNG Prcedure fr Statutry Ntificatins t DEHP, Landhlder, CG and DTE. This prcedure prvides guidance regarding the regulatry ntificatin prcess t the administering authrities f the applicable federal and state legislatin. The ntificatin cnditins f the relevant EAs als apply t emergency envirnmental incidents. Sants GLNG must ntify the DEHP Pllutin Htline as sn as reasnably practicable, but within the perid prescribed, after becming aware f an emergency envirnmental incident that is in cntraventin f EA cnditins. The ntificatin f emergency envirnmental incidents as required by the EAs ntificatin cnditins must be submitted t the administering authrity using an Incident Ntice. Fllw up reprting regarding incident details and impacts will als be required t be submitted t the administering authrity, in accrdance with EA cnditins. Page 14

20 6.4.3 Stakehlder Ntificatins Under the duty t ntify requirements f the EP Act, it is necessary t prvide written ntice t any ccupier f the affected land r any registered wner f the affected land regarding the event, its nature and the circumstances in which it happened within the prescribed time frame after becming aware f the event. Public ntificatin f the event, its nature and the circumstances in which it happened t persns n the affected land may als be required. It may be necessary t cmmunicate the state / type f the emergency, the pssible cause, its effects / cnsequences, likely duratin and impact t all ther ptential stakehlders. The emergency respnse and management teams may be required t liaise with regulatry authrities and ther stakehlder grups such as lcal cuncils, landwners and emergency services. All ther external stakehlder cmmunicatin shall be managed thrugh the Incident Operatins Centre (IOC) and may include lcal landhlders and cmmunity representatives, Sants emplyees and family members, custmers and prducers, media and insurers and lawyers. 6.5 Envirnmental Recvery Site Assessments If initial mnitring cnducted in respnse t an envirnmental release indicates the ptential fr envirnmental impact, a Cntaminated Site Assessment is t be cnducted t assess whether the site cntaminatin pses a ptential risk t human health and/r the envirnment (either n r ff the site), and if the release is f sufficient magnitude t warrant remediatin r a management cntrl apprpriate t the current r prpsed land use. On the basis f the release and ptential area f impact, an investigatin wrk plan will be develped. This wrk plan will cnsider the fluids / chemical released, the media impacts (land and/r water), and the envirnmental setting. Further details n Cntaminated Site Assessments can be fund within EHS 08 - Cntaminated Sites Remediatin and Rehabilitatin f Cntaminated Land If site assessments identify unacceptable risk assciated with impacts, Sants GLNG will implement management cntrls r cnduct remediatin and rehabilitatin f the affected media until the remaining risk is acceptable. The remediatin and rehabilitatin will be site specific and cnducted in accrdance with EHS 08- Cntaminated Sites and the Sants GLNG Upstream Rehabilitatin Management Plan. 6.6 Incident Investigatin Fllwing the annual training, and/r fllwing an actual incident, nn-cnfrmance and imprvements f the prcedures utlined in the ECP shall be identified and actin taken t remedy. Additinally, all incidents will be investigated t determine the casual factrs and assciated underlying systematic weaknesses (rt causes). The scpe and depth f an investigatin, including the cmpsitin f the investigatin team, shall be relative t the ptential severity f the cnsequences and/r risk level f the incident. The investigatin prcess is detailed in EHSMS 15 Incident Investigatin and Respnse and an abbreviated summary is presented belw: 1. Secure the investigatin sites and evidence; Page 15

21 2. Assign an investigatin team (varies based n type f investigatin); 3. Gather factual infrmatin; 4. Prepare a chart f events based n fact gathering; 5. Identify the casual factrs invlved; 6. Fr each casual factr, identify the rt cause (why the casual factr ccurred); 7. Recmmend crrective actins fr each rt cause; 8. Dcument the investigatin. Page 16

22 7.0 Evaluatin and Review 7.1 Evaluatin The implementatin and effectiveness f this management plan and any assciated prcedures will be regularly assessed t ensure: Sants GLNG is demnstrating cmpliance with legal and regulatry bligatins; The verall management strategy remains relevant and up t date; and The plan and prcedures adequately manage the envirnmental issue. Effectiveness can be assessed by a number f methds as shwn in Table 3. Table 3: Methds t Assess Legal and Prcedural Effectiveness Assessment Tl Checklists Sants GLNG Cmpliance Management System Descriptin Checklists, develped t reflect legal and prcedural requirements / utcmes will be used by individual Sants GLNG Departments t assess and manage cmpliance. The results f the checklists will be evaluated fr trending nncmpliances that may be reslved thrugh prcedural change r by implementing anther measure r prcess. Audits Cnduct internal and third party audits t frmally assess the level f cmpliance with bth regulatry requirements and with Sants GLNG prcedures. Audit utcmes are used t develp crrective actins which may include changes t this plan and/r prcedures. Review f Incidents A review f internal incidents, near misses r hazards will be undertaken t identify recurrences f similar incident types. This may highlight a requirement fr a change in the existing plan and/r prcedure, require the develpment f a new prcedure r by implementatin f anther measure r prcess t address the recurring issue. Review f Data Analyse all relevant data cllected fr negative and/r undesirable trends that may be prevented by prcedural changes r by implementing anther measure r prcess. 7.2 Review The ECP is a living dcument and shall be reviewed at least every three years r sner if any f the fllwing ccur: The plan is nt adequately managing the issue (refer Sectin 7.1); Legislative requirements change; and/r The area f activity changes. Reviews and changes t the ECP are t be cmmunicated t relevant Sants GLNG Prject persnnel. Page 17

23 8.0 Definitins Term Absrbent Checklists Cal Seam Gas water Cntaminatin Cntaminated Site Assessment Crisis Management Team (CMT) Dam EHSMS Emergency Emergency Envirnmental Incident Definitin A material that picks up and retains a liquid distributed thrughut its mlecular structure causing the liquid t swell (50% r mre). The absrbent is at least 70% insluble in excess fluid (ASTM F726-99). Checklists assist in assessing the implementatin f a Prcedure. Checklists cntain a list f key items required, things t be dne, r pints t be cnsidered and are a tl t assess cmpliance with a Prcedure. Grundwater brught t the surface f the earth, r therwise interfered with, in cnnectin with explring fr r prducing cal seam gas. Cal seam gas water is a waste, as defined under s13 f the EP Act. The cnditin f land r water where any chemical substance r waste has been added at abve backgrund level and represents, r ptentially represents, an adverse health r envirnmental impact. A frmal investigatin f a site t assess the ptential fr cntaminatin f sil and / r a water bdy (surface and grundwater) resulting in identificatin f cntaminatin levels. A team f nminated Sants senir management based in Adelaide wh will, where required, augment the capability ad skills f the Brisbane-based IMT. The Crisis Management Team Leader is respnsible fr crdinating the necessary resurces t supprt the IMT respnse and recvery effrts A land-based structure r a vid that is designed t cntain, divert r cntrl flwable substances, and includes any substances that are thereby cntained, diverted r cntrlled by that land-based structure r vid and assciated wrks. A dam des nt mean a fabricated r manufactured tank r cntainer, designed and cnstructed t an Australian Standard that deals with strength and structural integrity f that tank r cntainer. Sants Envirnment, Health and Safety Management System (EHSMS) frms the verall framewrk under which all Sants activities are undertaken. A site/field/area based unplanned event, accidentally r deliberately caused, which requires a respnse and which may result in: Injury t peple; Lss f cntrl f any aspect; Damage t the envirnment Lss f business; Lss r damage t prduct r assets; Lss f prductin; Disruptin t custmers; r The ptential fr any f the abve. An emergency envirnmental incident is a sudden, immediate threat t the public health, r the well-being f the envirnment, arising frm the release r ptential release f il, r hazardus chemicals int the air, land r water. Page 18

24 Term Emergency Operatins Centre (EOC) Emergency Respnse Team (ERT) Envirnmental Nearmiss Incident Incident Management Team (IMT) Incident Operatins Centre (IOC) Management Plan Prcedure Queensland Incident Management Plan (QIMP) Sants Crisis Management Plan (SCMP) Sants GLNG Upstream Prject Area Definitin A safe, site r field facility, lcal t the incident frm which the ERT perates in an emergency. It is set up as a cmmunicatin hub t the IOC and where the crdinatin f the respnse effrt and supprt fr the incident respnse is prvided. A team f nminated Sants persnnel wh perfrm asset specific incident management / supprt functins and assist the FRT. The ERT is determined by the Emergency Respnse Team Crdinatr upn activatin f the Emergency Operatins Centre. A near-miss incident typically des nt result in the same level f alarm as an emergency envirnmental incident. A near-miss is an event which, under slightly different cnditins, culd have resulted in injury, damage, envirnmental harm r business lss. A near-miss is an pprtunity t imprve management strategies based n a cnditin r an incident that had ptential fr a mre serius cnsequence. An event which requires immediate and crdinated actin t prevent r minimise injury, lss r damage. Incidents are classified accrding t the Incident Assessment Matrix frm Categry 1 (lwest impact) t Categry 5 (highest impact) A team f nminated Sants GLNG senir management and ther supprt persnnel based in Brisbane wh prvide supprt t the ERT. The lcatin where the IMT Leader and IMT members prvide verall directin f strategic respnse activities. Management Plans are specific t an envirnmental issue and/r tpic. They primarily serve t prvide a high level verview f the legislative and apprval requirements and the Sants GLNG management strategy in place fr the relevant envirnmental issue. Management Plans are als suitable fr prviding envirnmental regulatrs an verview f Sants GLNG envirnmental management, and in many cases, may be a direct requirements f an envirnmental apprval. Prcedures are designed t assist in the implementatin f the Management Plan, by prescribing a series f prcesses and actins fr a specific tpic. A clearly defined and dcumented prcedure that articulates the framewrk that shuld be applied in respnse t an incident. The SCMP dcuments the prcedures, facilities and rganisatinal rles / respnsibilities required t ensure that Sants is capable f effectively and efficiently managing a crisis (Categry 5 n the Incident Assessment Matrix). Cmprises all Sants GLNG explratin and prductin tenements f the Arcadia, Fairview, Rma and Sctia gas fields. Page 19

25 9.0 References Sants GLNG (2014) Upstream Management Plans Library Sants Ltd (2011) Queensland Incident Management Plan, Dc N: 3301-GLNG Sants Ltd (2012) CSG Drilling and Cmpletins Emergency Respnse Plan, Dc N: HS-DC864- PRO Sants Ltd (2012) GLNG Upstream Operatins Bushfire Management Plan, Dc N: 0020-GLNG Sants Ltd (2012) GLNG Upstream Operatins Emergency Respnse Plan, Dc N: PLA Sants Ltd (2012) Sants Crisis Management Plan Sants Ltd (2013) Envirnment, Health and Safety Management System Library Sants GLNG (2013) Prcedure fr Statutry Ntificatins t DEHP, Landhlder, CG and DTE Sants Ltd (2013) Sants GLNG Upstream Waste Management Plan, Dc N: 3301-GLNG Page 20