EVIDENCE OF

KUPE NZ LTD ON BEHAL

2698126

BEFORE THE ENVIRONMENTAL PROTECTION AUTHORITY

IN THE MATTER

AND

IN THE MATTER

EVIDENCE OF IAIN DAVID CURRILL FOR ORIGIN ENERGY RESKUPE NZ LTD ON BEHALF OF THE KUPE JOINT VENTURE P

2 APRIL 2014

J D K GardnerE L MathesonPhone +64 4 499 9555Fax +64 4 499 9556PO Box 10DX SX11189Wellington

EFORE THE ENVIRONMENTAL PROTECTION AUTHORITY

IN THE MATTER of the Exclusive Economic Zone and Continental

Shelf (Environmental Effects) Act 2012

IN THE MATTER of the Trans-Tasman Resources South Taranaki

Bight Offshore Iron Sand Project Marine Consent

Application

OR ORIGIN ENERGY RESOURCES KUPE JOINT VENTURE PARTIES

J D K Gardner-Hopkins/ E L Matheson Phone +64 4 499 9555 Fax +64 4 499 9556 PO Box 10-214 DX SX11189 Wellington

EFORE THE ENVIRONMENTAL PROTECTION AUTHORITY

Exclusive Economic Zone and Continental

Shelf (Environmental Effects) Act 2012

Resources South Taranaki

Bight Offshore Iron Sand Project Marine Consent

1

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EXECUTIVE SUMMARY

A. My full name is Iain David Currill. I hold a BE(Mech) 1st Class Honours

Degree and am currently NZ Technical Manager/Projects' Director for

Origin Energy based in New Plymouth.

B. I have over 25 years of engineering and project management experience

in the oil and gas industry, including over 10 years specifically in the

offshore installation contracting industry, and specific experience in the

Kupe and Maui fields.

C. Given this background and experience, I was extremely interested to

review Trans-Tasman Resources' (TTR) submission and their proposed

seabed mining concept.

D. My initial review of the information provided as part of their EPA marine

consent application has left me concerned that the potential risk and

impacts of TTR's proposed operations on the existing Kupe interests and

infrastructure have not been adequately identified nor considered.

E. Whilst there is uncertainty as to the level or probability of some of the

concerns (potential effects) identified by Origin, I consider further analysis

is essential to prove that there is no impact nor risk and I believe that the

onus should be on TTR to prove no impact prior to them being permitted

to commence mining operations.

F. Based on my previous experiences with marine and offshore operations

in the Kupe area and based on the limited information provided in their

application, I consider TTR would be well served to complete further

detailed and specific vessel mooring and workability analyses to prove

the viability of their concept.

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1. INTRODUCTION

Experience and qualifications

1.1 My full name is Iain David Currill. I am currently the NZ Technical

Manager at Origin and also have a role as the NZ Projects' Director for

Origin. My statement of evidence is presented on its behalf.

1.2 In my role at Origin I manage the activities of the NZ based Engineering

and Project Delivery team(s) to support the operation of Origin's New

Zealand facilities. I have been in my current role for around two years but

immediately prior to that was responsible for what was then a separate

project delivery team until this was combined with the

technical/engineering team approximately two years ago.

1.3 I have, however, been associated with Origin and the Kupe facilities,

specifically the offshore elements of the project, since 2006. I was

involved with the Kupe Alliance (which designed, constructed and

delivered the completed Kupe facilities to Origin) prior to the final FID

(Final Investment Decision) sanction of the project and have remained

associated with it ever since.

1.4 One of the key responsibilities of my current role is to ensure the ongoing

technical integrity of Origin's New Zealand facilities. This responsibility

manifests across a broad range of activities ranging from ongoing

inspection and audit programmes to ensuring that any modifications

made to the facilities are completed to the appropriate and required

standard(s) and subject to the appropriate level and breadth of review.

1.5 This responsibility extends to ensuring that third party works that may

affect Origin facilities are appropriately reviewed to ensure that there is no

impact or increased risk to existing Origin facilities as a result of the

project, or, if a potential risk is identified, ensuring that this can be

mitigated or ideally eliminated.

1.6 Another of my key responsibilities is the oversight of any significant

project works completed on Origin's NZ facilities, both Kupe and the

onshore Rimu and (now divested) TAWN facilities.

1.7 A range of project works have been completed by Origin over recent

years including three significant offshore campaigns associated with the

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Kupe pipeline, EHU (Electro-Hydraulic Umbilical) and WHP (Wellhead

platform). Further information on these campaigns is provided below.

1.8 In addition to the above, my experience and qualifications, as relevant to

this proposal, are as follows:

(a) BE(Mech) 1st Class Honours.

(b) I have been working as an engineer and/or project manager in

the oil and gas industry for over 25 years in New Zealand and

Australia. A significant portion of my experience (more than 10

years) has been working in the offshore and subsea

construction industry firstly with Clough-Stena Joint Venture,

then Coflexip Stena and then Technip (although these are all

essentially the same company; there were just a number of

ownership/name changes). During this time I acted as Project

Engineer and then Project Manager on a range of

offshore/subsea projects in the Oceania region including BHPP's

Griffin FPSO development, BHPP's Challis 14 project,

Woodside's Lambert Hermes project and STOS' Maui B FPSO

installation.

(c) In 2002 I elected to return to New Zealand and joined SKM and

then Beca and worked as a Project Manager on a range of

projects, including a secondment back to Technip (Perth) in

2004 as Bid Manager for their tender for the design and

construction of the offshore Pohokura facilities. Technip's

tender was successful but I was not involved in the execution of

the project.

(d) In April 2006 I was asked by Technip to become Project

Manager - Pipelines involved in the final definition stages of the

Kupe project when Technip, as part of the Kupe Alliance, was

working to complete the final project definition prior to Origin

(and the Kupe JV partners) taking their FID decision. (The

overall Kupe Alliance was broken down into three sub projects;

pipelines, platform and onshore facilities.)

(e) Whilst working as Project Manager - Pipelines within the Kupe

Alliance, I was responsible for the definition and specification of

all elements of the pipeline and associated EHU (Electro-

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Hydraulic Umbilical) between the shore and Kupe WHP

including material selection and specification, selection of the

technique(s) to be used to ensure the long-term in-place stability

of the raw gas pipeline and EHU, as well as the associated

construction methods to be used.

(f) With the Kupe project having passed FID and the scope of the

pipeline project defined, I elected to return to New Zealand in

2007 but remained involved with the Kupe project, managing a

number of elements of the project including the HDD (Horizontal

Directional Drilling) shore crossings.

(g) I elected to join Origin (from the Kupe Alliance) in 2008 and

have remained with Origin since that time.

(h) I am a current member of IPENZ (Institute of Professional

Engineers New Zealand) and PMI (Project Management

Institute).

Background to involvement

1.9 I have been aware of the Trans-Tasman Resources Iron Sands project

since 2013, although I can't recall exactly when I became aware of it.

1.10 I have had no dealings with TTR on their proposal.

1.11 Prior to the preparation of this statement of evidence, I had only a broad

understanding of what TTR intended to do, based primarily on information

that had been published in the Taranaki Daily News and other press

reports.

1.12 Whilst not having detailed knowledge of TTR's intentions or proposed

recovery methods, my initial reaction - given my knowledge and

experience of working in the Kupe area - was that I thought their proposal

was optimistic given the environmental and metocean conditions that they

would likely encounter.

1.13 As a result of various discussions, meetings and correspondence within

Origin I subsequently became aware that TTR's proposed mining area

overlapped the Kupe mining permits. This immediately flagged concerns

of the potential impact on the Kupe facilities.

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1.14 Prior to preparing this statement of evidence, I have had no material

involvement in preparing any information or submissions to either TTR,

New Zealand Petroleum and Minerals (NZPAM), the EPA or any other

party relating to the TTR proposal and Origin's response to it; this had all

been handled by Vicki Meijer and Tony Bissell.

1.15 Specifically in respect of the marine consent application that is the subject

of this proceeding, and as part of the preparation of this statement of

evidence, I have read the following information and evidence:

(a) Origin's submission;

(b) TTR's South Taranaki Bight Iron Sands Project Impact

Assessment Summary;

(c) key sections of the application material;

(d) TTR's further information response, in particular section 3.3;

(e) the following evidence on behalf of TTR:

(i) Tim Crossley;

(ii) Ian Ives (transhipping operations);

(iii) Oceanographic processes, including Gary Teear's

evidence on jack-up rigs;

(iv) Matt Brown (resource and exploration process);

(v) Shawn Thompson (operational issues);

(vi) Martijn Schouten (marine mining); and

(vii) Dr Mike Patrick (risk assessment/management);

(f) Joint Statement of Experts in the Field of Effects on Waves and

Surfing;

(g) Joint Statement of Experts in the Field of Effects on Bathymetry

and Oceanographic Processes;

(h) the EPA independent technical review of reports in respect of:

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(i) effects on navigation (North and Trew); and

(ii) effects on oceanographic processes (SKM); and

(i) the EPA independent effects assessments in respect of effects

on oceanographic processes.

1.16 I have also read the evidence produced by Tony Bissell and Reneke van

Soest on behalf of Origin and cross refer to that evidence where relevant.

2. SCOPE OF EVIDENCE

2.1 In my evidence I address the current operations undertaken by Origin on

behalf of the Kupe JV. I provide information about:

(a) the background and initial installation of the Kupe facilities;

(b) an overview of our current operations and mining equipment;

and

(c) the potential impacts of the TTR activities on our current

operations (including the costs/losses associated with any

disruption to those operations).

2.2 As detailed in the evidence of Tony Bissell, Origin have engaged AMOG

to complete a detailed independent technical review of TTR's submission.

As Mr Bissell explains, that is both to provide a 'litmus test' to the

reasonableness of the concerns we are raising though this process, but

also to assist with our engagement with NZPAM and TTR on the issues

into the future (for example in the context of any coordination agreement).

I have completed my review with a focus on those areas within TTR's

proposal where I consider there to be a risk to Origin's existing Kupe

interests as opposed to a technical review of the material.

2.3 As indicated in this evidence, there are a number of areas where I

consider that TTR is yet to adequately demonstrate that its activities do

not result in an unacceptable increase in the risk to Origin's existing Kupe

interests.

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3. CURRENT OPERATIONS AT THE KUPE FIELD

Establishment of the current operations and infrastructure

3.1 A general outline and description of the Kupe facilities is included in the

evidence provided by Tony Bissell, Origin Energy's Commercial Manager.

As such, I have not repeated that information here.

3.2 I would, however, like to provide some additional background and detail

information relating to the subsea facilities. This includes information as

to the investigations prior to establishing the Kupe Wellhead Platform

(KWHP) and the raw gas pipeline and umbilical between the KWHP, their

construction, and the challenges faced in respect of construction and

early operation.

3.3 The KWHP is connected to the onshore production facility via an

approximately 30km long 12" raw gas pipeline and 6" EHU. The pipeline

and EHU run through two separate HDD (Horizontal Directionally Drilled)

shore crossings that exit approximately 1200m offshore (KP28.2) and in

14m water depth (LAT). From the HDD exits, the pipeline and EHU run

for approximately 2400m through a boulder field (to KP25.8) before they

reach a 'sandy' seabed for the remaining approximately 26000m to the

KWHP.

3.4 Locations and points along the pipeline are identified in terms of "pipeline

kilometre points" or pipeline KP's. Whilst there are separate KP's and

references for the pipeline and EHU (given their slightly different paths),

for convenience most references are to pipeline KP's: KP0 is at the

KWHP, KP25.8 at the offshore end of the boulder section, and KP28.2 at

the point at which they enter the HDD shore crossing.

3.5 One of the significant challenges facing the project prior to FID in 2006

was to determine a workable and cost effective design and installation

methodology for the raw gas pipeline and EHU given the relatively

shallow water depths and prevailing metocean conditions.

3.6 The metocean criteria utilised for the design of the Kupe facilities were

defined in a 2004 report prepared by ASR: Kupe MetOcean Design

Criteria Environmental Statistics for Design, ASR Report Number 5510-

02, November 2004 (Origin Report Number OF0401-REP-00-G-0001 Rev

1). That report is attached to my evidence as Appendix 1.

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3.7 That report indicated that there were very few periods where there was

not (at least) moderate swell/wave activity and that the swell/wave activity

there was essentially mono-directional with the majority of the waves

coming from the South-West. As such, the prevailing (wave) weather

direction was 45-90° to the pipeline route; the worst possible direction for

maintaining vessel workability during any offshore installation activity.

3.8 The selection of a 'reel lay' pipeline installation method using a

specialised pipeline installation vessel - the CSO Apache - was critical in

achieving an economically viable solution. Unlike conventional pipeline

installation techniques that use a moored or dynamically positioned (DP)

vessel (commonly referred to as a 'lay barge') to join individual pipe

lengths together as they are laid into final position on the seabed, the

reel-lay pipeline installation methodology utilises specialist vessels such

as the CSO Apache to spool pipe that has been welded into continuous

lengths of up to 11km (in the case of Kupe) onto a large reel on the

vessel. The pipe is then 'unreeled' onto the seabed as the vessel moves

along the required pipeline route.

3.9 This reel lay installation methodology transfers the significant time

activities of welding, NDT (non-destructive testing to prove the quality of

the welded connections) and field jointing coating ('patching' the anti-

corrosion coating at the pipeline and the points where the sections have

been welded together) from the vessel working offshore to an onshore

spool base.

3.10 The reel lay methodology was selected as it significantly reduces the time

the pipeline installation vessel is required to be on-site and the

consequent exposure to weather downtime. (Weather downtime is

defined as that time during which environmental/metocean conditions

prevent the vessel from working.)

3.11 Whilst I can't remember the exact figures, my recollection is that the initial

assessments of the Kupe metocean conditions indicated that likely

weather downtime for a typical conventional lay barge that could lay the

12" line in the Kupe location and water depths were in the order of 25-

30%. Given that - from memory - the times estimated (excluding weather

downtime) for a conventional lay barge installation were in the order of

10x that for a reel lay methodology, this obviously equated to significant

extra costs for the project; the assessments were that the project was not

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economically feasible should it have to bear these higher installation

costs.

3.12 The metocean conditions identified for the Kupe WHP site and pipeline

route also indicated that the project faced significant challenges in

identifying and executing a suitable stabilisation methodology (or

methodologies) for the raw gas pipeline and EHU.

3.13 The techniques/methodologies available for stabilising subsea pipelines

(or any object located on the seabed) can be broadly split into two

categories; those that physically separate the pipeline from the effects of

the waves (eg. burial) and those that make the object heavy enough to

withstand the loads imposed by the movement of the waves.

3.14 Whilst it was identified that the seabed in the offshore section of the

pipeline (nominally from KP0 to KP25.8) was suitable for burying, the

section through the boulder field from KP25.8 to KP28.2 (the HDD shore

crossings entry) was not.

3.15 After considerable assessment of the metocean design conditions and

associated baythmetry and technical analysis of the options available, the

decision was taken to stabilise the section of pipeline and EHU that runs

through the boulder field area by strapping the EHU to the pipeline and

then using external weight mattresses to stabilise the pipeline and EHU.

3.16 This solution requires that both the straps holding the EHU and the

weight mattresses are strong/heavy enough to withstand the

(environmental) loads imposed from the metocean conditions.

3.17 The Ensco 107 jack-up drill rig (JUR) was used to install the KWHP jacket

and topsides and to drill and complete the (currently) three production

wells that run through casings on the KWHP. A 100m x 37m 'dumb'

installation barge was used to transport the KWHP jacket structure and

topsides to the location to be lifted and installed using the Ensco 107

JUR. A temporary four point mooring system was installed on the barge

and used to hold the barge in position. Extensive mooring analyses were

completed on this barge and suggested mooring line loads of ≈ 90te in Hs

= 2.0m seastates.

3.18 I have been unable to locate any detailed vessel workability analyses or

mooring assessments in the information and evidence provided by TTR.

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I acknowledge that the key focus of TTR's submission to date has been

on environmental factors, however, my previous experiences in working

in the Kupe area - as outlined in this evidence - leave me concerned that

further work is required in these key areas to mitigate the potential for any

future 'surprises'. I further acknowledge that completion of these detailed

analyses may allay my concerns. I note, however, that similar queries

were raised in the North and Trew Review of technical reports relating to

TTR marine consent application - navigation report.

3.19 Following completion of the Kupe construction and drilling campaign(s),

the Ensco 107 was moved to the Momoho well location to the South-East

of the KWHP. The Momoho well location is just to the South of TTR's

proposed marine consent area.

3.20 Prior to moving the Ensco 107, however, a detailed geotechnical

investigation - including a borehole - was completed on the proposed

jack-up location to confirm its suitability for founding the rig; this is

'standard operating procedure' prior to operating a jack-up rig in a new

location. As indicated in his evidence, Mr Gary Teear was involved with

New Zealand Diving and Salvage in the completion and evaluation of this

borehole.

3.21 A Remotely Operated Vehicle (ROV) survey completed in April 2011

indicated that an isolated (small) number of the straps that were installed

to secure the EHU to the pipeline had failed. Origin immediately

commenced an investigation into the failure of the clamps; the results of

this investigation indicated that the seabed topography to the south east

of the Kupe pipeline and wellhead had a considerable localised effect on

the metocean conditions experienced at varying points along the Kupe

pipeline and that, as a result, the initial metocean BOD was too 'coarse' in

the manner in which it broke down the varying metocean conditions in the

30km between the shore and the KWHP location.

3.22 A detailed side scan sonar bathymetric survey of the seabed area to the

south east of the pipeline route and KWHP location was completed as

part of the investigation. The results are detailed in Fugro BTW report P-

11018-RA-022, Fugro BTW Final Survey Report Side Scan Sonar

Survey. As well as providing invaluable data on the seabed topography

in previously 'un-surveyed' areas 'up-weather' of the Kupe facilities, the

survey also indicated that there had been considerable local change in

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the seabed topography along the previously surveyed pipeline route; this

indicated that there was significant and ongoing movement of the seabed

in the area.

3.23 This survey data was utilised by MetOcean Solutions in a full re-analysis

of the metocean conditions along the Kupe pipeline route and WHP

location. The scope for this reanalysis was described by MetOcean

Solutions in their technical note dated 18 June 2012, and summarised in

MetOcean Solutions Report P0098-02 Kupe Field Metocean Conditions

2012 Review of Environmental Data for Offshore Facilities. The

methodology used to confirm these data is further described in MetOcean

Solutions Report P0098-01 Kupe Metocean Conditions Hindcast Methods

and Validation Results. These reports are attached as Appendix 2,

Appendix 3 and Appendix 4.

3.24 Whilst the 'extreme' metocean conditions remained essentially

unchanged (meaning that it was not necessary to revise the BOD per se)

the re-analysis work highlighted the sensitivity of the metocean conditions

to the 'up-weather' seabed topography and the variability along the

pipeline route as a result of changes in seabed topography. The

reviewed metocean data also highlighted that much of the wave and swell

activity, although relatively low in 'height' is relatively long in period and is

therefore quite 'energetic'.

3.25 As detailed in the following paragraphs, three offshore works campaigns,

including inspection surveys, have been completed in the Kupe field

following its commissioning in Dec 2009:

(a) A September - December 2011 campaign in the near-shore

(boulder field) section of the pipeline and EHU (approx. 1- 2.6km

offshore) completed using the "Seawatch" and a number of

support vessels. This first campaign, completed with smaller,

moored vessels, took considerably longer than subsequent

campaigns due to the significantly reduced workability (and

increased weather down-time) of the smaller, moored vessel(s).

(b) A February 2012 campaign using the DP "DSV Skandi

Singapore" that covered primarily the near shore section of the

pipeline.

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(c) A February 2013 campaign again involving the DP "DSV Skandi

Singapore" that covered the full length of the pipeline and EHU

as well as jacket inspection works.

3.26 These subsea campaigns highlighted changes to the seabed profile (and

consequently burial depth) along the pipeline and umbilical route as well

as some evidence of seabed movement (scour) at the KWHP location.

3.27 A similar effect was also observed around the WHP with the seabed

profile and bathymetry at the base of the KWHP and in the surrounding

area showing evidence of localised scouring; whilst not of immediate

concern, it is an area that Origin will continue to monitor during future

inspection campaigns and is considered evidence of the impact of local

variations in the surrounding seabed baythmetry.

3.28 As I explain below, our previous experience with the seabed conditions

and topography and how they appear to be changeable (following

surveys) means that we are wary of activities being undertaken nearby

that will change the local wave climate and seabed currents.

The existing mining permit and value of current activities

3.29 Tony Bissell provides details as to the current mining permit under which

the Kupe JV operates and information as to the current value of its

assets. I do not repeat or expand on that information here.

4. POTENTIAL IMPACTS ON KUPE JV

General

4.1 Whilst I acknowledge that the details and requirements of the marine

consenting process are outside my area of expertise, I was surprised that

TTR's submission (Section 13.4 - Effects on Existing Interests) included

little if any discussion on the potential impact of their operations on the

existing Kupe interests as I assumed that, similar to the RMA consent

process, they would have to demonstrate no adverse impact on existing

interests (or at least how any impacts would be appropriately avoided,

remedied, or mitigated including through conditions as to liability).

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Collision events

4.2 As indicated above, I am concerned that I have been unable to identify

any specific information or studies within TTR's application or evidence

that specifically address the vessel workability and operational limits and

associated mooring system requirements for the FPSO. Due to my

previous experience in offshore construction operations, including

specifically in the Kupe area, I am concerned that these key areas are

ones in which TTR may be being somewhat optimistic in their

assumptions. I acknowledge that detailed analyses may well resolve my

concerns but, as indicated, I have been unable to identify such analyses

nor acknowledgement of their potential importance in the information

submitted by TTR.

4.3 The KWHP, and specifically the jacket (or supporting structure), is only

designed to withstand an accidental impact from a slow moving (0.5m/s

or ≈ 1kts) 1000 tonne (displacement) vessel operating in close proximity

to the platform (ref OF0401-BOD-30-S-0001 - Structural Design Criteria,

Wellhead Platform). All of the vessels proposed by TTR as part of the

mining operation are significantly larger than the 1000 tonne

displacement vessel assumed in the KWHP impact calculations.

4.4 Any other more significant vessel impact to the KWHP - particularly if the

vessel is large enough to strike the platform topsides - is likely to result in

significant structural damage to the KWHP. Any significant structural

damage is likely to require the KWHP to be shut-in (and production

ceased) until the damage can be repaired.

4.5 The subsea pipeline and EHU are extremely susceptible to damage as a

result of impact from a dragged anchor or any other subsea equipment.

4.6 Although buried for the majority of their length, the depth of cover (the

depth the pipeline/EHU is buried below the surface) is only around 300-

600mm; this is unlikely to be sufficient to prevent the pipeline/EHU being

caught by a dragged anchor from TTR's proposed processing (or

another) vessel.

4.7 Should the (steel) pipeline be impacted by a dragged anchor (or

equivalent), the resultant damage is likely to range from a 'dent' to a full

failure of the pipeline; due to the number of variables involved it is

difficult, if not impossible, to define the criteria under which the pipeline

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would be 'dented' rather than ruptured. Future production opportunities

are outlined by Reneke van Soest in her statement.

4.8 In any event, any impact to the pipeline would require production to be

shut-in and the pipeline to be de-pressured, inspected and, if required,

repaired prior to production resuming.

4.9 Should the EHU be impacted by a dragged anchor (or equivalent), the

resultant damage is most likely to be a complete failure of the EHU as it is

much weaker than the pipeline.

4.10 In this instance, production would likely be shut-in until the entire EHU

could be replaced; there is no known industry precedent for the in-situ

repair of an analog umbilical.

4.11 The above discussion refers to damage from a dragged anchor or

equivalent as this is likely to be the 'worst case' scenario. An impact from

the crawler unit also has the potential to compromise the integrity of the

pipeline or EHU.

4.12 Areas of the proposed TTR mining area result in the FPSO being located

up-weather of and in fairly close proximity to the Kupe facilities. I

consider that the potential for damage to the existing Kupe facilities from

an (unplanned) incident associated with TTR's activities to represent a

credible risk scenario that should be addressed. The only evidence of

this risk having been addressed within TTR's submission is on risk

included in Table 13 - TTR HAZID Workshop Risk Assessment - of TTR's

marine consent A=application. I have cut and pasted the risk below.

4.13 I am concerned that not only does the TTR Risk Assessment only include

one risk relating to the impact of its operations on the existing Kupe

facilities but also that the manner in which TTR has treated the 'residual

risk' rating is not consistent with standard industry practice. Standard

industry practice - certainly that followed within Origin - is that whilst a

mitigation(s) or 'control' can reduce the likelihood of a risk event occurring

they do not - and arguably cannot - reduce the consequence should the

control fail. For the example pasted above (and there are other similar

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examples within the risk assessment), it is accepted that the controls

proposed would reduce the likelihood but the consequence must remain

at "Catastrophic"; this would result in a residual risk rating of "High".

4.14 The seabed mining area proposed by TTR overlaps areas where Origin

(or previous Operators of the Kupe PML) have either drilled and

abandoned exploration wells or plan to drill future development

(production wells).

4.15 Impact from a dragged anchor (or equivalent) onto one of these

wellheads has the potential to compromise the integrity of both the

wellhead and, in a worst case, the well casing itself.

4.16 An impact from the crawler unit also has the potential to compromise the

integrity of the wellhead although it is acknowledged that this is likely to

be a less significant incident than an impact from a dragged anchor.

4.17 Unfortunately, due to the number of variables involved it is difficult, if not

impossible, to define the criteria or conditions which would result in a

'material' failure; standard industry practice is to try and prevent any

impact to a wellhead through the imposition of safety exclusion zones

(such as the 500m zone around the Kupe Platform).

Undermining of current infrastructure

4.18 As indicated, the various bathymetric surveys and subsequent reviews

and revisions of the metocean BOD for the pipeline route and KWHP

location have indicated that there is significant variation in local metocean

conditions along the pipeline route and at the KWHP depending on the

'up-weather' seabed topography and that areas of the seabed topography

appear to be 'mobile' and constantly changing.

4.19 As such, Origin is concerned that the significant changes to the 'up-

weather' seabed topography as a result of TTR's proposed activities will

result in significant changes to the metocean conditions seen along

(sections of) the pipeline route and at the KWHP with a consequent

impact on the loadings imposed on the pipeline and umbilical and the rate

of scour (seabed 'erosion') around the base of the KWHP. Unfortunately,

due to the number of variables involved it is difficult, if not impossible, to

define the criteria or conditions which would result in a 'material' change.

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4.20 TTR's application (eg. Section 11.1.2 of the marine consent application)

indicates that the mining activities will have an impact on the local wave

climate; I note that Dr Richard Gorman at paragraph 84 of his primary

statement of evidence briefly addresses the concerns raised by Origin in

respect of changed currents and wave reflections. However, Dr Gorman's

comments appear to only reference the effects on the local wave climate

from the FPSO, not from the changes to the seabed topography as a

result of TTR's proposed mining operations. As such, I consider it by no

means a comprehensive or robust evaluation. Given that the Kupe

assets - both the KWHP and pipeline/EHU are the closest existing

interests/infrastructure to TTR's proposed activities I believe TTR need to

complete further analyses to demonstrate that there will be no impact on

the existing Kupe interests. At a minimum, conditions need to be imposed

that will require TTR to establish appropriate baseline data, and monitor

as it commences and continues its activities. Ultimately, however, even

such a monitoring campaign provides no guarantee that there will not be

adverse impacts on the existing Kupe interests, namely the KWHP, raw

gas pipeline and EHU.

Visibility

4.21 I have similar concerns in respect of underwater visibility. Whilst Dr

Hadfield has produced additional information in his summary statement of

evidence circulated on 28 March 2014, it is important for the decision

making committee to understand what that means practically.

4.22 For example, a subsea visibility of at least 5m to is generally regarded as

the minimum necessary to efficiently complete an ROV survey. Whilst an

ROV survey can be completed with less visibility than this, it becomes

significantly less efficient and there is, obviously, an increased risk of

potential issues or anomalies being missed.

4.23 I have not been able to find any information in the TTR application and

evidence that addresses how frequently the visibility at the Kupe Platform

or along the pipeline will be less than 5m during mining activities, or for

how long such conditions will exist.

Effects on Future Infrastructure

4.24 As outlined in Reneke van Soest's statement of evidence, it is most likely

that, if not able to be drilled from the KWHP location, any future

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production wells associated with the Kupe project (linked into the Kupe

raw gas pipeline) would be located to the South-East of the KWHP; this

would place them either in or beyond the area proposed to be dredged by

TTR. Any such production wells would be linked back to the KWHP with

a subsea pipeline and EHU.

4.25 Whilst it is difficult to quantify the exact impact, any requirement to locate

the jack-up rig for future development wells in areas that have been

dredged and back-filled by TTR is undoubtedly going to require

significantly more geotechnical investigation and analysis than a well

location in un-disturbed seabed. I have read Mr Teear's evidence and

whilst not technically incorrect it could be said to present a somewhat

optimistic view of the residual impact of the TTR mining operations on the

seabed. Despite what Mr Teear says, it is not beyond consideration that

the nature and depth of backfill, and the time required for this to settle

and consolidate, will make it not possible to safely and economically

found a jack-up rig in areas that have been disturbed and back-filled by

TTR's activities.

4.26 Similarly, whilst it is difficult to quantify the exact impact, any requirement

to run the production pipeline and control EHU for future development

wells through areas that have been dredged and back-filled by TTR is

undoubtedly going to require significantly more geotechnical investigation

to ensure that the pipeline and EHU can be safely installed and stabilised.

4.27 As such, both of these factors represent a potentially significant - but as

yet unquantifiable - risk to Origin's ability to safely and effectively

complete the future development of the Kupe and related fields.

Costs of stopped production

4.28 Details relating to the future value of the Kupe assets and the costs

associated with any stoppage to production from the Kupe assets are

included in the evidence provided by Mr Tony Bissell; as such, I have

elected not to duplicate this information.

4.29 However, I do wish to reiterate that Origin considers it appropriate that

conditions are placed on the marine consent that require TTR to

demonstrate that there is no impact on the existing Kupe interests from

their activities or, as a minimum, that they are obliged to consult with

Origin and take all steps to mitigate any potential effects. Related to this,

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I would consider it not unreasonable that TTR are required to obtain

appropriate insurance cover to compensate the Kupe JVPs should any

loses arise from TTR's activities (as well as to remedy any wider

environmental damage).

5. CONCLUSION

5.1 As detailed above, my initial review of the information provided as part of

TTR's EPA marine consent application has left me concerned that the

potential risk and impacts of TTR's proposed operations on the existing

Kupe interests and infrastructure have not been adequately identified nor

considered.

5.2 Whilst there is uncertainty as to the level or probability of some of the

concerns (potential effects) identified by Origin, I consider further analysis

is essential to prove that there is no impact or risk and I believe that the

onus should be on TTR to prove no impact prior to them being permitted

to commence mining operations.

5.3 Based on my previous experiences with marine and offshore operations

in the Kupe area, and considering the limited information provided in

TTR's application I consider that TTR would be well served to complete

further more detailed and specific vessel mooring and workability

analyses to prove the viability of their concept.

Iain David Currill 2 April 2014

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Appendix 1 - Kupe Metocean Design Criteria Environmental Statistics for Design

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Appendix 2 - MetOcean Solutions technical note

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Appendix 3 - Kupe Field Metocean Conditions 2012 Review of Environmental Data for Offshore Facilities

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Appendix 4 - Kupe Metocean Conditions Hindcast Methods and Validation Results