Gladstone Ports Corporation

Transcription

1 Third Party Compliance Audit: Western Basin Dredging and Disposal Project Approval Coordinator-General s Imposed itions Audit Number: 2012/07 July 2012 Prepared by

2 Coordinator General s Report for EIS itions Contents 1. EXECUTIVE SUMMAR INTRODUCTION SUMMAR OF REVIEW PROCESS AUDIT BACKGROUND PURPOSE SCOPE REVIEW PROCESS ISSUES TO BE CONSIDERED IN REVIEWING THIS REPORT SUMMAR OF FINDINGS NON COMPLIANCES PARTIAL COMPLIANCES COMPLIANCES PREVIOUS NON COMPLIANCES PREVIOUS PARTIAL COMPLIANCES CONCLUSIONS Audit Checklist Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 2 of 25

3 Coordinator General s Report for EIS itions Abbreviations ASSMP CSD DEHP DERM DMP EBSDS EIS ERA FFMP GED GPC LNG TSHD VODI JV WBDDP WBRA WQMP Acid Sulfate Soil Management Plan Cutter Suction Dredge Department of Environment and Heritage Protection (formerly DERM) Department of Environment and Resource Management Dredge Management Plan Eastern Bank Sea Disposal Site Environmental Impact Statement Environmentally Relevant Activity Flora and Fauna Management plan General Environmental Duty Gladstone Ports Corporation Liquefied Natural Gas Trailer Suction Hopper Dredge Van Oord (Australia) Pty Ltd and Dredging International (Australia) Pty Ltd Joint Venture Western Basin Dredging and Disposal Project Western Basin Reclamation Area Water quality Management Plan Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 3 of 25

4 Coordinator General s Report for EIS itions Third Party Compliance Audit Report PROJECT: Western Basin Dredging and Disposal Project AUDIT NUMBER 2012/07 Audit Date June 2012 ADDRESS: Gladstone Ports Corporation Gladstone QLD PERSONS CONTACTED: Mick Jorgensen GPC Project Manager Anjana Singh Environmental specialist (Auditing and Compliance Reporting) Dwayne Ford GPC Construction and Monitoring Specialist Melanie Sutton Water Quality Environment Specialist GPC Siebe Veenstra Environmental Superintendent) VODI JV Daniel Spooner Environmental Lead-Parcel 5 AUDIT TEAM MEMBERS James Hart, AQUAS, Lead Auditor Joseph Cacdac, AQUAS, Auditor SSTEM STANDARD: Coordinator-General s Report Western Basin Dredging and Disposal Project, Schedule 3 Coordinator General s Imposed itions SCOPE OF AUDIT: Compliance with Schedule 3 Coordinator General s Imposed itions Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 4 of 25

5 Coordinator General s Report for EIS itions 1. EXECUTIVE SUMMAR This report has been prepared following an audit of the Western Basin Dredging and Disposal Project (WBDDP) being undertaken by Gladstone Ports Corporation (GPC) for compliance with the Schedule 3 - Coordinator-General s imposed conditions, coordinator General s Report for an environmental Impact statement, July The audit was conducted in conjunction with the fourth round of the DERM Permit SPDE audit, which commenced on 19 June 2012 and ended with a closing meeting on 21 June The audit team, comprising James Hart and Joseph Cacdac (AQUAS), interviewed representatives of GPC and the Principal Dredging Contractor. The principal dredging contractor is a joint venture between Van Oord (Australia) Pty Ltd and Dredging International (Australia) Pty Ltd (VODI). The findings of this audit report confirm that GPC have generally complied with the requirements of the Coordinator-General s imposed conditions. Activities being undertaken at the time of audit were: Minor works on construction of the emplacement area bund wall; Backhoe dredge operations; CSD dredge operations Dumping of spoil in the onshore emplacement area; and Dumping of spoil in the offshore disposal area. GPC and VODI JV has developed documentation and implemented measures to address the requirements of the imposed conditions, and provided evidence to verify general compliance with the imposed conditions and environmental management plans. Issues raised during the previous audit were followed up to assess the implementation of corrective actions identified. It was found that one non-compliance and all partial noncompliances had been satisfactorily addressed. For the non-compliance raised against Imposed ition 8, it was found that actions had been implemented which partially addressed the issues raised. This non-compliance was downgraded to a partial compliance in the current audit. GPC s and VODI s commitment to environmental management and ensuring compliance with the approvals conditions was evidenced through the resources provided for environmental management of the project, their openness and availability during the audit process, proactive management of turbidity levels, and rapid response to and thorough investigation of environmental incidents which have occurred. All persons interviewed were courteous and open, and quickly responded to issues identified during the audit process. No non-compliances were raised during this audit. Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 5 of 25

6 Coordinator General s Report for EIS itions Four areas of partial compliance were raised. These are identified in the Table following. Issue No. ition Requirement Issue sighted P-01 4 The EMP must include all project commitments made by proponent in the EIS, SID and other impact assessment documentation, and all conditions arising from the project s approval and subsequent permits, authorities and/or licences P-02 5 In addition to the provisions of the draft EMP (provided as Chapter 19 of the EIS),specific requirements must be included for: a) Flood events, cyclone and storm surge b) Seagrass monitoring and studies c) Shorebirds d) Waste P-03 8 All relevant components of the EMP that relate to the operation of the Port of Gladstone must be incorporated into the GPC environmental management system P The proponent must, when first becoming aware of a non-compliance of any Coordinator- General imposed condition: a) Authorize and undertake action to bring the matter into compliance within an effective timeframe as approved by the Coordinator- General Requirements have not been clearly identified in the EMP. However, DMP and associated documents do include approval conditions. Requirements of the EIS and SID have been incorporated into the Dredge Management Plan. Specific requirements have not been included in the EMP, although requirements are included in Table 2 of the DMP. The legal and other requirements associated with the WBDDP had not been included in the Corporate EMS. Letter to DEEDI 6/10/11 responding to non-conformances raised. Response not provided within 5 business days. b) Report the non-compliance and remedial action to the Coordinator-General within 5 business days of becoming aware of the noncompliance. We note and acknowledge the cooperation and assistance of Gladstone Ports Corporation and VODI personnel during the process of this audit. Report prepared and authorised by James Hart (Lead Auditor) Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 6 of 25

7 Coordinator General s Report for EIS itions 2. INTRODUCTION Gladstone Ports Corporation (GPC) is managing the dredging of Gladstone Harbour under the Western Basin Dredging and Offshore/Onshore Disposal Project (WBDDP) which is intended to create a shipping channel to be utilised by LNG proponents on Curtis Island to expand shipping capacity and support the emerging liquefied natural gas (LNG) industry. This involves dredging an anticipated 25 million m 3 of material, with disposal being split between the Western Basin Reclamation Area at Fisherman s Landing and the offshore disposal area. The Project is being completed on behalf of various LNG proponents. The WBDDP was declared a state significant project by the Coordinator-General (CG) on 24 April Two locations have been identified for the disposal of dredged material, onshore disposal at the emplacement area at Fisherman s Landing constructed by Abigroup, and offshore disposal at the GPC s existing disposal area just outside of the Gladstone Harbour entrance. As part of the Coordinator-General s conditions of consent, GPC require third party auditing to assess compliance the Coordinator-General s imposed conditions. This report presents the findings of the third party audit conducted in conjunction with the quarterly audit of the DERM Permit No SPDE itions of Approval undertaken on June SUMMAR OF REVIEW PROCESS 3.1. Audit Background As a condition of Coordinator-General s approval of the WBDDP issued in July 2010, GPC LNG require third party auditing of compliance with the compliance the Coordinator-General s imposed conditions (Schedule 3 Imposed itions). ition 30 of the Schedule 3 conditions of approval state: The following third party auditing requirements must be applied for the project: a) Compliance with the Coordinator-General s imposed conditions of this report must be audited by an appropriately qualified and experienced third party auditor or auditors appropriate to the matters being audited, nominated by the proponent and accepted by the Coordinator-General, within one year of the project receiving approval to proceed and annually thereafter b) The proponent must submit the third party audit report to the Coordinator-General within 42 days of the end of the relevant period c) The audit report must identify the segment of the project being audited, the conditions that were activated during the period, and a compliance/ non-compliance table. A description of the evidence to support the compliance table must be provided. The audit report will also contain recommendations on any non-compliance or other matter to improve compliance. The third party auditor must certify the findings of the audit report d) The financial cost of the third party audit is borne by the proponent Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 7 of 25

8 Coordinator General s Report for EIS itions e) The holder of the environmental authority must immediately act upon any recommendations arising from the audit report and: i) Investigate any non-compliance issues identified ii) as soon as practicable, implement measures or take necessary action to ensure compliance with this authority f) Subject to condition 25(a) and not more than 30 calendar days following the submission of the audit report, the proponent must provide a written advice to the Coordinator-General addressing the: i) Actions taken by the proponent promptly and routinely to ensure compliance with the Coordinator-General s imposed conditions ii) Actions taken to routinely prevent a recurrence of any noncompliance issues. GPC have commissioned AQUAS to undertake the third party audits as required under this condition Purpose The purpose of this audit is to fulfil the requirements as stipulated in condition 30 of the approval and to provide feedback to GPC on any areas of non-conformance, partial compliance or improvement suggestions Scope The audit scope covers a general review of GPC LNG organisation and procedures to implement the environmental management plans, including its management of the contractor engaged to carry out dredging and disposal of dredge spoil onto the onshore and offshore disposal locations. An audit checklist was developed based on Schedule 3 - Coordinator-General s imposed conditions Review Process The audit commenced with an Opening Meeting to confirm the scope, purpose and timeline of the audit. This was held at 08:30am, 19 June 2012 in the GPC LNG RG Tanna site office. The audit involved a review of GPC LNG and contractor (VODI) records, site inspection and interviews with project personnel. A site inspection/ audit of dredging activities was undertaken on Wednesday 20 June 2012 on board the cutter suction dredge Al-Mahaar, and the hopper barge Pieter Caland. The site inspection included an inspection of the vessel and environmental response equipment, chemical storage facilities, review of documentation and records available on the vessel and interviews with vessel personnel. The audit included an inspection of the WBRA area on Tuesday 19 June 2012 by the auditor, Joseph Cacdac, accompanied by Mr Dwayne Ford. The ongoing deposition of dredge material at the south west corner of WBRA was observed. Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 8 of 25

9 Coordinator General s Report for EIS itions A closing meeting was held on Thursday 21 June 2012 where the preliminary audit findings were presented to GPC LNG and VODI Issues to be considered in reviewing this report This audit was based on a review of compliance with the approval conditions for the construction and operation of dredging operations and associated infrastructure. In particular, the audit focused on the implementation of measures described in the Dredge Management Plan and associated documentation to address the conditions of consent and manage the impacts of the construction of the emplacement area and dredging operations on the marine environment of the Gladstone port. The checklist appended to this report identifies those compliance issues that could be assessed given the stage of the project. By its very nature an audit does not guarantee full compliance of all aspects of the project with the undertakings of the Dredge Management Plan and associated documentation. In the opinion of the audit team however, the extent and scope of the field inspection together with the records maintained by GPC and VODI there was sufficient evidence to verify general compliance of the activities with the requirements of the Dredge Management Plan and associated documents, and the conditions of approval. 4. SUMMAR OF FINDINGS Activities being undertaken at the time of audit were: Minor works along the eastern bund wall (Bund A); Cutter suction dredge operations; Backhoe dredge operations Dumping of spoil in the onshore emplacement area; Dumping of spoil in the offshore disposal area. GPC s and VODI s commitment to environmental management and ensuring compliance with the approvals conditions was evidenced through the resources provided for environmental management of the project, their openness and availability during the audit process, proactive management of turbidity levels, and rapid response to and thorough investigation of environmental incidents which have occurred. All persons interviewed were courteous and open, and quickly responded to issues identified during the audit process. Information was obtained through review of hard copy records and electronic records maintained by GPC and VODI, interviews with relevant personnel and observations during site inspections. A site inspection of the WBRA was undertaken on Tuesday 19/06/12 by Joseph Cacdac accompanied by Dwayne Ford of GPC and Siebe Veenstra of VODI. During the inspection, the placement of dredge material along the south west bund wall was observed. A site inspection was undertaken on Wednesday 20 June 2012, during which records and implementation of environmental controls were reviewed on the CSD Al Mahaar and the hopper barge Pieter Caland. During the site inspection, it was noted that persons interviewed had a good understanding of project requirements, particularly in relation to fauna management, chemical Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 9 of 25

10 Coordinator General s Report for EIS itions handling and storage, and waste disposal. A good range of waste receptacles were available which allowed for the safe storage and segregation of waste streams, and spill kits were noted to be available in appropriate locations on board vessels. Maintenance records and records of dredging activities were readily available, including both areas of dredging and disposal. Records were also available to show that prestart briefings and toolbox training and emergency response training (including spill response) had been undertaken. Information on fauna, incident response and emergency response procedures were also readily accessible Non-compliances No non-compliances were raised as a result of the audit Partial Compliances Four partial compliances were raised as a result of the audit. Issue No. ition Requirement Issue sighted P-01 4 The EMP must include all project commitments made by proponent in the EIS, SID and other impact assessment documentation, and all conditions arising from the project s approval and subsequent permits, authorities and/or licences P-02 5 In addition to the provisions of the draft EMP (provided as Chapter 19 of the EIS),specific requirements must be included for: e) Flood events, cyclone and storm surge f) Seagrass monitoring and studies g) Shorebirds h) Waste P-03 8 All relevant components of the EMP that relate to the operation of the Port of Gladstone must be incorporated into the GPC environmental management system P The proponent must, when first becoming aware of a non-compliance of any Coordinator- General imposed condition: c) Authorize and undertake action to bring the matter into compliance within an effective timeframe as approved by the Coordinator-General Requirements have not been clearly identified in the EMP. However, DMP and associated documents do include approval conditions. Requirements of the EIS and SID have been incorporated into the Dredge Management Plan. Specific requirements have not been included in the EMP, although requirements are included in Table 2 of the DMP. The legal and other requirements associated with the WBDDP had not been included in the Corporate EMS. Letter to DEEDI 6/10/11 responding to non-conformances raised. Response not provided within 5 business days. d) Report the non-compliance and remedial action to the Coordinator-General within 5 business days of becoming aware of the non-compliance. Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 10 of 25

11 Coordinator General s Report for EIS itions 4.3. Compliances All other conditions relevant to this approval were found to be either compliant or not applicable Previous non-compliances Non-compliances identified during the previous audit conducted in July 2011 were followed up as part of this audit NCR No. ition Requirement Issue sighted Status Current Audit 01 8 All relevant components of the EMP that relate to the operation of the Port of Gladstone must be incorporated into the GPC environmental management system The proponent must, prior to the commencement of construction: a) Identify and assess all risks to maritime safety and ship-sources pollution relating to all stages of the project (i.e. bund construction of the RHM and MSQ) b) Define required mitigation measures for identified risks and include details in the following management plans to the satisfaction of the RHM and MSQ: i) vessel traffic service management plan ii) aids to navigation management plan iii) ship-sourced pollution prevention management plan c) Consult with DTMR through MSQ and RHM when preparing the management plans and take account of the reviews and incorporate any proposed amendments d) Discuss funding arrangement for new and modified maritime infrastructure and systems requirements resulting from the project with DTMR through MSQ and the RHM? At the time of the audit it was understood that the GPC EMS had not been specifically updated in line with the project EMP. The GPC EMS is currently under review, particularly the legal and aspects and impacts register An up-to-date risk register was not reviewed by the auditor. The aspects and impacts register of the EMP is to be updated as discussed in response to condition 8. No specific GPC developed vessel and traffic service management plan or aids to Navigation Management Plan were viewed by the auditor. However, GPC and/or VODI were noted as preparing plans relevant to the specific identified high-risk activities (e.g. Unloading the Al Mahaar CSD) and discussing these plans in a regular weekly project meeting with the RHM. It was further noted that GPC must comply with the MSQ prepared Standards of Marine Construction Activity within Gladstone Harbour and Port Procedures and Information for Shipping: Port of Gladstone. The Corporate EMS had been updated to include reference to the WBDDP, EMP and impact register. However, the legal and other requirements associated with the WBDDP had not been included in the Corporate EMS. Raised as P-01 Risk register available (updated 22/06/12). Letter sighted from GPCL to DEEDI following audit in September 2011 in which GPCL stated that a Vessel Management Plan was not appropriate as MSQ have a Gladstone Harbour Vessel Management Plan which would make redundant any vessel management plan prepared by GPCL. Response from DEEDI (27/02/2012) did not require any further action on behalf of GPCL in relation to preparation of a Vessel Management Plan. While an Aids to Navigation Management Plan had not been prepared, it was noted that a Dumping Management Plan prepared by VODI JV included Navigational Traffic Management identifying equipment, routes, and communication. Navigation aids were discussed in weekly meetings between MSQ and GPC. It was also noted that the MSQ Guidelines for Major Development Proposals (22/09/10) requires a Vessel Traffic Service Management Plan, Aids to Navigation Management Plan and Ship- Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 11 of 25

12 Coordinator General s Report for EIS itions NCR No. ition Requirement Issue sighted Status Current Audit Sourced Pollution Prevention Management Plan to be developed prior to development approval to allow for effective assessment of proposed developments. Closed 4.5. Previous Partial compliances Issue No. ition Requirement Issue sighted Status Current Audit P All proposed management plans in relation to DTMR shall incorporate a provision to ensure that, prior to commencing any program of works, the proponent will consult with DTMR through MSQ and the RHM, and take account of the reviews and incorporate any proposed amendments. P The holder of this authority must telephone the DERM s Pollution Hotline ( ) or local office as soon as practicable after becoming aware of any release of contaminants or any event where environmental harm has been caused or may be threatened. The Dredge Management Plan does not implicitly note that the plans will be reviewed by the RHM or his comments incorporated. However, the auditor did note that GPC (and their principal contractor VODI JV) are meeting with the RHM on a weekly basis to discuss the program of works in order to seek feedback. Two oil spill incidents have occurred to the marine environment during the audit period, resulting in the release of approximately 100ML (ml?) to marine waters on 2 July 2011 and five litres on 4 July There was evidence supplied to the auditor that the DERM Pollution or the DERM Gladstone Office was contacted in relation to the incidents. However, the incident reports refer to the Gladstone Harbour Control Pollution Hotline being informed on each incident date within 1.5 hours of the incident and appropriate spill mitigation strategies being put in place. DMP Appendix A approval itions compliance Table includes requirement for GPC to comply with this condition. Records of weekly meetings between GPC, VODI and the RHM were available to show ongoing consultation. Closed. SEWPaC were notified in a brief Closed on the 4 July 2011 regarding both instances. DERM and SEWPaC were also provided details via incident notification reports, as evidenced by an dated 18 July The VODI Environment Incident Register was sighted. It contained 41 entries for the period 04/07/11-13/06/12. The VODI procedure for reportable incidents is to immediately notify the RHM, the EPA Hotline and GPC, with the date and time of notification recorded in the incident report. The EPA reference number for the reported incident is also noted. The Environmental Notification Report for Incident #40 (unplanned dumping and oil spill on 7 and 8 June 2012) was sighted. Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 12 of 25

13 Coordinator General s Report for EIS itions 5. CONCLUSIONS On the basis of the findings of this audit, it is considered that GPC and its contractor VODI have generally complied with the requirements of the approval conditions and requirements of the environmental management plans for activities carried out to date. ATTACHMENTS: Audit Attendance Sheet Audit Checklists CIRCULATION: Gladstone Ports Corporation AQUAS Pty Ltd Report issued by on Thursday, 26 July 2012 Distribution: Anjana Singh (GPC LNG) Mick Jorgensen (GPC LNG) Audit Report: AQ Audit-Coordinator Generals imposed conditions June 2012 Rev 0 Page 13 of 25

14 1 Audit Checklist Schedule 3 -Coordinator- General s imposed conditions Part 1 EMP general 1 The project must be carried out generally in accordance with the Western Basin Dredging and Disposal Project Environmental Impact Statement (EIS) (November 2009) for the project, and the Western Basin Dredging and Disposal Project EIS Supplementary Information Document (SID) for the project (April 2010), and Appendices 1 and 2 of this report (see Schedule 1, ition 6). 2 The proponent (or the proponent s contractors) must finalise the project environmental management plan (EMP) to the satisfaction of DERM prior to commencement of operational works for the project 3 The EMP must be based on the draft EMP (provided as Chapter 19 of the EIS). Western Basin Dredging and Disposal Project Environmental Management Plan LNG-0000-EM-PL-0001 sighted. Approved 8/03/12. Risk register available _GPC-WBSD-Risk Register_V4 EMP available References to risk management process in the EMP incorrect (Ref to Appendix 5, actually in App 6&7. Organisation chart has not been updated to reflect current structure. Roles and responsibilities in section 6.2 do not clearly show individual roles and responsibilities Requires updating to reflect current structure and responsibilities. EMP provided is not specifically based on the draft EMP, however the EMP is consistent with the requirements for EMP as per AS 14001:2004. P 4 The EMP must include all project commitments made by proponent in the EIS, SID and other impact assessment documentation, and all conditions arising from the project s approval and subsequent permits, authorities and/or licences Risk register available does not include all the risks which were identified in the Draft EMP (e.g. CSD operations, TSHD operations). Requirements have not been clearly identified in the EMP. However, DMP and associated documents do include approval conditions. Requirements of the EIS and SID have been incorporated into the Dredge Management Plan. P 01 Audit Report AQ /06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 14 of 25

15 5 In addition to the provisions of the draft EMP (provided as Chapter 19 of the EIS),specific requirements must be included for: i) Flood events, cyclone and storm surge j) Seagrass monitoring and studies k) Shorebirds l) Waste 6 The proponent and/or its contractor(s) must undertake any tidal operational works in accordance with all requirements of the approved EMP or any subsequently endorsed amendments to that plan (see Schedule 2). 7 The proponent must conduct all works to ensure that no environmental harm as defined under the Environmental Protection Act 1994 is caused (see Schedule 1, Part 4). 8 All relevant components of the EMP that relate to the operation of the Port of Gladstone must be incorporated into the GPC environmental management system Not included in the EMP However, included in Table 2 of the DMP Works in accordance with the DMP. Included in Section of the Western Basin DMP Operational control updated to include the Project EMP. The GPC environmental management system legal and other requirements register had not been updated to include specific requirements associated with the WBDDP. P 02 P 03 Part 2 Transport 2.1 Cumulative marine transport impacts 9 12 months prior to the first operations of LNG shipping tankers the proponent must prepare and submit to DTMR/Maritime Safety Queensland (MSQ) and the Regional Harbour Master Gladstone (RHM), for review, approval and subsequent implementation, a marine traffic management plan for vessel traffic management services required in Port Curtis during the construction and dredging for the project 10 The proponent must identify all aids to navigation and/or vessel traffic management services that will be required for this project and in the cumulative management of shipping in Port Curtis, in accordance with the plans required by condition 9. Not as yet 12 months prior to the start of operations of LNG shipping tankers (approx. 2014) Pre-agreed set of markers have been installed - shown on harbour map. Matters relating to floating plant and navigation aids are covered in weekly coordination meetings between GPC, VODI and the MSQ. For example, the weekly coordination meeting minutes for 23/02/2012 included installation of new cyclone moorings. NA Audit Report AQ /06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 15 of 25

16 Audit Report AQ Marine safety The proponent must ensure that safety of navigation must be maintained 11 during all stages of development. Navigation aids are to be provided as specified by the RHM and MSQ. 12 The proponent must, prior to the commencement of construction: All activities are undertaken in consultation with MSQ. MSQ track all vessels in the port. Navigations aids provided as per RHM and MSQ instructions has not been required as yet. Matters relating to floating plant and navigation aids are covered in weekly coordination meetings between GPC, VODI and the MSQ. e.g. Installation of additional lights on bund walls, items 10/11 13/06/12. Risk register available (updated 22/06/12). a) Dredge Management Plan includes management a) Identify and assess all risks to maritime safety and ship-sources measures for operations. pollution relating to all stages of the project (i.e. bund construction of Risk register includes: the RHM and MSQ) Shipping b) Define required mitigation measures for identified risks and include RISK ID 113: Delay in relocating navigation aids. details in the following management plans to the satisfaction of the RHM and MSQ: RISK ID : Inclement weather threatens dredge worker and i) vessel traffic service management plan public safety ii) aids to navigation management plan RISK ID 125: Major accident between vessels causing equipment iii) ship-sourced pollution prevention management plan damage and personal injury c) Consult with DTMR through MSQ and RHM when preparing the RISK ID 070 : Barge places dredge spoil outside the Eastern management plans and take account of the reviews and incorporate Banks Offshore Disposal Site may cause fines to the Project. any proposed amendments RISK ID 97.1 : Serious Safety breach d) Discuss funding arrangement for new and modified maritime Pollution infrastructure and systems requirements resulting from the project with RISK ID 149: Grease balls formed by dredges delay production DTMR through MSQ and the RHM? due to concern by DEHP. RISK ID 64: Fuel or hydraulic fluid release occurs requiring clean up and an incident report. RISK ID 162: Waste (rubbish, ballast, equipment) lost into the harbour RISK ID 163: Chemical release from onboard storage or deck wash down/environment clean up causes risk to the environment. RISK ID 164: Release of sewage from vessel into the harbour causes risk to the environment and health issues /06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 16 of 25

17 Thee risk assessment includes identification of controls to minimise identified risks. No specific GPC developed vessel and traffic service management plan, aids to Navigation Management Plan or shipsourced pollution prevention management plan were available. Letter sighted from GPCL to DEEDI following audit in September 2011 in which GPCL stated that a Vessel Management Plan was not appropriate as MSQ have a Gladstone Harbour Vessel Management Plan which would make redundant any vessel management plan prepared by GPCL. Response from DEEDI (27/02/2012) did not require any further action on behalf of GPCL in relation to preparation of a Vessel Management Plan. Dumping Management Plan had been prepared by VODI JV which included Navigational Traffic Management identifying equipment, routes, and communication. While an Aids to Navigation Management Plan had not been prepared, it was noted that navigation aids were discussed in weekly meetings between MSQ and GPC. It was also noted that the MSQ Guidelines for Major Development Proposals (22/09/10) requires a Vessel Traffic Service Management Plan, Aids to Navigation Management Plan and Ship-Sourced Pollution Prevention Management Plan to be developed prior to development approval to allow for effective assessment of proposed developments. c. Records of ongoing meetings with MSQ were sighted. d. Reported that all costs for new and modified maritime infrastructure and systems requirements resulting from the project are borne by GPC. Budget sighted Audit Report AQ /06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 17 of 25

18 13 Audit Report AQ Within three months of appointing a construction contractor for the project, and prior to the commencement of any construction works on the project, the proponent will: a) Finalize and submit to MSQ and RHM, and any other relevant parties for review and approval, an assessment of maritime safety and ship-sourced pollution potential impacts and mitigation requirements of the project. The assessment of impacts and provision of mitigation measures should ensure that navigational safety and ship based-pollution prevention is maintained at all times for the life of the project. Information should include, but not limited to: i) DMP including the type, size and operation of ships associated with the proposed dredging activity ii) detailed information about any plans to dispose of dredged material offshore (as outlined in section 17.2 of the SID), specifically any impacts on marine safety iii) detailed information about cumulative impacts of related projects (as outlined in section 19.8 of the SID), specifically any impacts on marine safety iv) plans to ensure construction lighting does not adversely impact on the effectiveness of Aids to Navigation in the area and the bund wall, outlined in the section 16 of the EIS supplementary information document, is appropriately lit to advise mariners of the obstruction to navigation b) Prepare a management plan for new or upgraded aids to navigation and/ or vessel traffic management services required by the project. DTMR must approve the plan prior to implementation c) Provide/ upgrade all aids to navigation and/ or vessel traffic management services required by the project d) Liaise with the RHM to update the Gladstone Pilotage Area Port Procedures and information to shipping manual to reflect the changes to navigation areas in Gladstone Harbour and determine what restrictions on shipping are required to support the construction of this project and ensure marine safety is maintained e) The proponent will detail and undertake all identified resolutions in the proponents statement of commitments 19-21/06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 18 of 25 a) See condition 12 b) See condition 12 c) Weekly meetings are held with RHM at which operational matters, including navigation and vessel traffic management services are discussed. d) Weekly meetings are held with RHM e) Refer to response to condition 4 and remainder of this table.

19 14 All proposed management plans in relation to DTMR shall incorporate a provision to ensure that, prior to commencing any program of works, the proponent will consult with DTMR through MSQ and the RHM, and take account of the reviews and incorporate any proposed amendments. 2.3 Cumulative marine transport impacts months prior to the first operations of LNG shipping tankers the proponent must prepare and submit to DTMR (MSQ) and the RHM, for review, approval and subsequent implementation, a marine traffic management plan for vessel traffic management services required in Port Curtis during the construction and dredging for the project The proponent must identify all aids to navigation and/or vessel traffic management services that will be required for this project and in the cumulative management of shipping in Port Curtis, in accordance with the plans required by condition 14. The Chief Executive of DTMR is the entity responsible for this condition Part 3 Land Use 3.1 Strategic Port Land Use Plan 17 Once the reclamation is complete, the proponent must seek an amendment to the Strategic Port Land Use Plan (in accordance with section 285 of the Transport Infrastructure Act 1994) to include a requirement that all future development on the reclaimed area is in accordance with Civil Aviation Safety Authority (CASA) requirements, such as CASA s Manual of Standards Part Aerodromes, including issues such as building and infrastructure height restrictions/ limitations and lighting. 3.2 Sterilization of mineral resources 18 The proponent shall maintain satisfactory communication with QER and DIP during the WBDD Project to sure that QER s interests are not adversely affected. The Chief Executive Officer of GPC is the entity with jurisdiction for this condition Requirement not specifically included in the management plans. However, weekly meetings are held with MSQ and RHM. Management plans are provided to MSQ and RHM for review. Not as yet 12 months prior to the start of operations of LNG shipping tankers (approx. 2014) Pre-agreed set of markers have been installed - shown on harbour map. Matters relating to floating plant and navigation aids are covered in weekly coordination meetings between GPC, VODI and the MSQ. For example, the weekly coordination meeting minutes for 23/02/2012 included installation of new cyclone moorings. Not as yet (due on 28/03/2014) Reported to be part of the Fisherman s Landing Stakeholder meeting. P N/A Audit Report AQ /06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 19 of 25

20 Part 4 Environmental Offsets 4.1 Marine Habitat Offset 19 Prior to the commencement of dredging works for the WBDD Project, GPC must: a) Submitted documentation to the satisfaction of the Coordinator- General that the agreed offset for marine fish habitat, as referenced in section 6.3 of the QBDD Project CG s report dated July 2010 has been secured b) If condition 19(a) cannot be achieved, submit for approval to the Coordinator-General an alternative offset proposal that is equivalent to or better than the agreed offset for marine fish habitat. 4.2 Commercial fisheries offset GPC must mitigate all reasonable financial losses to existing commercial fishing operators attributable to the maritime development in the Western Basin of the Port of Gladstone. This is to cover temporary and permanent loss of access to fishing areas and marine fish habitat GPC must meet any costs associated with the investigation, negotiation and administration of any compensation package, including all costs incurred by DEEDI in the management of development of any compensation package. The Chief Executive Officer of DEEDI is the entity with jurisdiction for these conditions 4.3 Recreational fishing and boating offset 22 Prior to the completion of stage 1 dredging works, GPC shall contribute funding and/or works to the value of $1 million towards new or upgraded recreational fishing infrastructure within the Gladstone region as determined by DTMR. A further $0.5 million of funding will be provided for all tide public boat ramps within the Western Basin area prior to the completion of the stages 2 and 3 dredging. The Chief Executive Officer of DTMR is the entity with jurisdiction for these conditions Ongoing consultation via John Sherrif (GPC) was occurring to finalise agreement on the offsets. The Western Basin Dredging and Disposal Project V3 (11/05/12) includes SEWPaC and Coordinator General s conditions. Steering committee set up in July-August The Biodiversity Offset Strategy will combine biodiversity offset strategy and marine coastal biodiversity offset. It was reported that GPC wee in negotiations to unify the requirements for offsets as required by SEWPaC and DEEDI. It was reported that all costs associated with the investigation, negotiation and administration of any compensation package are met by GPC. GPC have provided 2 boat ramps, one on /Brian Jordan Drive and one at the bund wall. Cost of boat ramps not reviewed. Audit Report AQ /06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 20 of 25

21 4.4 Marine and coastal biodiversity offset 23 In addition to the provisions required for a flora and fauna management plan (FFMP) stated by conditions in Appendix 1, Schedule 2, Part 4 of this report, GPC shall provide additional offset measures for shorebirds and marine fauna to be included in the FFMP. These should consist of funding and/or in-kind contributions to the value of at least $2 million towards measures including, but not be limited to. a) Enhanced understanding of the displacement of key marine fauna species from affected habitat areas in Western Basin and any associated effects on regional populations b) Contribution to species protection programs in the region or the wider bioregion. This may include funding of additional boating and fisheries patrols, education campaigns for recreational fishers on risks of marine fauna boat strike and improved management of key shorebird habitat areas. c) Contribution to habitat enhancement/ restoration actions in the region of wider bioregion such as seagrass friendly mooring systems, wetland rehabilitation projects and water quality movement programs. Part 5 Complaint monitoring, management and response 5.1 Noise complaint monitoring management and response 24 In the event of a complaint, the proponent will: a) In the first instance change procedures to reduce noise that is the cause of the nuisance complaint b) Liaise with DERM and/ or complainant over remedial action Western Basin Dredging and Disposal Biodiversity Offset Strategy provided to SEWPaC in October from Paul Sullivan to DEEDI (Robert Warrell) and response sighted shows ongoing discussion re offset strategy. No noise complaints have been received N/A Audit Report AQ /06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 21 of 25

22 25 Where the actions of condition 19 do not resolve the noise issue, and when requested by the administering authority, noise monitoring will be undertaken to investigate any complaint of environmental noise nuisance and the results notified within 7 days to the administering authority. Monitoring must include: a) LAmax, adj T b) LAN, T (where N equals statistical levels of 1, 10 and 90) c) The level and frequency of occurrence of impulsive or tonal noise d) Atmospheric conditions including temperature, relative humidity and wind speed and direction e) Effects due to extraneous factors Does the method of measurement and reporting of noise levels comply with the latest edition of the DERM Noise Management Manual? 5.2 Managing complaints If the administering authority advises the holder of a complaint alleging nuisance (e.g. caused by light, dust or noise), the holder must investigate the complaint and advise the administering authority of the action proposed or undertaken in relation to the complaint If the administering authority is not satisfied with the proposed or completed action, the holder must undertake monitoring or other action requested by the administering authority Maintain a record of complaints and incidents causing environmental harm, and actions taken in response to the complaint or incident. Retain the record of complaints required by this condition for five (5) years 5.3 Complaint response 29 The holder of this authority must record the following details for all complaints received and provide this information to the administering authority on request: a) Time, date, name and contact details of the complainant b) Reasons for the complaint c) Any investigations undertaken d) Conclusions formed e) Any actions taken. No noise complaints have been received N/A No complaints have been received N/A No noise complaints have been received N/A No noise complaints have been received N/A Complaints register maintained by VODI and GPC. Both registers have provision for required information. N/A Audit Report AQ /06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 22 of 25

23 Part 6 Compliance and auditing The following third party auditing requirements must be applied for the project: a) Compliance with the Coordinator-General s imposed conditions of this report must be audited by an appropriately qualified and experienced third party auditor or auditors appropriate to the matters being audited, nominated by the proponent and accepted by the Coordinator-General, within one year of the project receiving approval to proceed and annually thereafter b) The proponent must submit the third party audit report to the Coordinator- General within 42 days of the end of the relevant period c) The audit report must identify the segment of the project being audited, the conditions that were activated during the period, and a compliance/ noncompliance table. A description of the evidence to support the compliance table must be provided. The audit report will also contain recommendations on any non-compliance or other matter to improve compliance. The third party auditor must certify the findings of the audit report d) The financial cost of the third party audit is borne by the proponent e) The holder of the environmental authority must immediately act upon any recommendations arising from the audit report and: i) investigate any non-compliance issues identified ii) as soon as practicable, implement measures or take necessary action to ensure compliance with this authority f) Subject to condition 25(a) and not more than 30 calendar days following the submission of the audit report, the proponent must provide a written advice to the Coordinator-General addressing the: i) actions taken by the proponent promptly and routinely to ensure compliance with the Coordinator-General s imposed conditions ii) actions taken to routinely prevent a recurrence of any noncompliance issues. The proponent must, when first becoming aware of a non-compliance of any Coordinator- General imposed condition: e) Authorize and undertake action to bring the matter into compliance within an effective timeframe as approved by the Coordinator-General f) Report the non-compliance and remedial action to the Coordinator- General within 5 business days of becoming aware of the noncompliance. Audit completed August Western Basin Dredging and Disposal Biodiversity Offset Strategy by CQG Consulting. Report submitted 1 September Letter sighted from DEEDI to GPC (3/10/11) identifying that no action plan had been provided within 30 days to DEEDI. Letter to DEEDI 6/10/11 responding to non-conformances raised. Letter sighted from DEEDI to GPC (3/10/11) identifying that no action plan had been provided within 30 days to DEEDI. Letter to DEEDI 6/10/11 responding to non-conformances raised. P 04 Audit Report AQ /06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 23 of 25

24 Part 7 Incident Management The holder of this authority must telephone the DERM s Pollution Hotline ( ) or local office as soon as practicable after becoming aware of any release of contaminants or any event where environmental harm has been caused or may be threatened. Subject to condition 28, the holder of this authority is required to report in the case of uncontained spills (including fuel lubricants, hydraulic fluid or other chemicals) of the following volumes or kind: a) Releases of any volume to water b) Releases of volume greater than 200 liters to land c) Releases of any volumes where potential serious or material environmental harm is considered to exist. The VODI Environment Incident Register was sighted. It contained 41 entries for the period 04/07/11-13/06/12. The VODI procedure for reportable incidents is to immediately notify the RHM, the EPA Hotline and GPC, with the date and time of notification recorded in the incident report. The EPA reference number for the reported incident is also noted. The Environmental Notification Report for Incident #40 (unplanned dumping and oil spill on 7 and 8 June 2012) was sighted. 25/04/12 Incident Report sighted minor oil spillage. Shows harbour Master, Environmental engineer, GPC and DERM pollution hotline notified. 16/05/12 Incident reported am. Report completed on 16/05/12 (incident 038). Final report for incident completed 29/05/12. 7/06/12 incident reported 5.20pm. Awaiting final report Audit Report AQ The notification of emergencies or incidents as required by conditions 28 and 29 must include but not be limited to the following: a) The holder of the authority b) Location of the emergency or incident c) Number of the authority d) The name and telephone number of the designated contact person e) The time of release f) The time the holder of the authority became aware of the release g) The suspected cause of release h) Actions taken to prevent any further release and mitigate any environmental harm caused by the release. Not more than fourteen (14) days following the initial notification of an emergency or incident, written advice must be provided of the information supplied in accordance with condition 29 in addition to: a) Proposed actions to prevent a recurrence of the emergency or incident; and b) Outcomes of actions taken at the time to prevent or minimize the environmental harm Incidents reports provide a detailed summary of the incident and corrective actions taken. It was noted that, while earlier incidents reports did not always clearly identify preventative actions, preventative actions have been identified for latter incidents (e.g. Incident No 030, Oil Spill on Razende Bol included action to replace hoses every 6 months). 25/04/12 Incident Report sighted minor oil spillage. Shows harbour Master, Environmental engineer, GPC and DERM pollution hotline notified. 16/05/12 Incident reported am. Report completed on 16/05/12 (incident 038). Final report for incident completed 29/05/ /06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 24 of 25

25 36 37 As soon as practicable, but not more than six (6) weeks following the conduct of any environmental monitoring performed in relation to the emergency or incident, which results in the release of contaminants not in accordance, or reasonably expected to be not in accordance with the conditions of this authority, written advice must be provided of the results of any such monitoring performed to the administering authority A record of incidents must be maintained to include a record of all incidents occurring in the previous five (5) years. The Coordinator-General is the entity with jurisdiction for these conditions No monitoring following an emergency or incident has been required. Records are maintained and readily available. Audit Report AQ /06/12 Audit Compliance Codes: : Compliance achieved; N: Non-compliance; P: Partial compliance; NA: not applicable at time of audit; OI: Opportunity for Improvement Page 25 of 25