project sea dragon - ntepa

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PROJECT SEA DRAGON CORE BREEDING CENTRE AND BROODSTOCK MATURATION CENTRE SUPPLEMENTARY ENVIRONMENTAL IMPACT STATEMENT

Project Sea Dragon Core Breeding Centre and Broodstock Maturation Centre Supplementary Environmental Impact Statement

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CONTENTS

Abbreviations and Acronyms ................................................................................ 1

1 Introduction ................................................................................................... 3

1.1 Purpose of this Document ...................................................................................... 3

1.2 Structure of this Document .................................................................................... 3

1.3 Project Overview .................................................................................................... 3

1.4 Summary of the Assessment Process .................................................................... 6

2 Summary of Submissions ................................................................................ 8

3 Response to Submissions .............................................................................. 11

3.1 Department of the Attorney-General and Justice - NT Worksafe ....................... 11

3.2 Department of Chief Minister .............................................................................. 13

3.3 Department Environment and Natural Resources ............................................... 15

3.4 Department of Health - Environmental Health Branch ....................................... 31

3.5 Department of Health - Medical Entomology ...................................................... 32

3.6 Department of Infrastructure, Planning and Logistics ......................................... 34

3.7 Department of Primary Industry and Resources ................................................. 38

3.8 Department of Tourism and Culture - Heritage Branch....................................... 38

3.9 Department of Tourism and Culture - Parks and Wildlife ................................... 40

3.10 Department of Tourism and Culture - Tourism NT .............................................. 40

3.11 Department of Trade, Business and Innovation .................................................. 41

3.12 Environment Centre ............................................................................................. 41

3.13 Ian and Pat Stewart .............................................................................................. 46

3.14 Northern Territory Environment Protection Authority ....................................... 49

3.15 Power and Water Corporation ............................................................................. 84

3.16 R.A. White ............................................................................................................. 84

3.17 University of Technology Sydney ......................................................................... 90

4 References .................................................................................................... 92

LIST OF TABLES Table 1 Number of Submissions Received from Stakeholders ..................................................................... 8 Table 2 Number of Comments Received from each Submitter .................................................................... 9 Table 3 Performance Requirements for Numerical Hydrodynamic Models in Estuaries and Coastal Areas

(United Kingdom Environment Agency 1998) ............................................................................... 16 Table 4 Biting Insect Management Strategy .............................................................................................. 33 Table 5 Operational Phase Traffic Summary .............................................................................................. 37 Table 6 Summary of Exclusion Practices Incorporated within the Design ................................................. 60


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Table 7 Aspects of the ASC Standard That Will be Incorporated into Operations at the Level of Conformance to Principles ............................................................................................................. 64

Table 8 Cardwell Operation Discharge Water Quality – Licence Conditions and Actual Performance ...... 71

LIST OF FIGURES Figure 1 Project Sea Dragon Component Locations ...................................................................................... 5 Figure 2 Summary of Issues Raised during the Public Comment Period ..................................................... 10 Figure 3 Benthic Habitat and Seagrass Mapping of Bynoe Harbour............................................................ 19 Figure 4 Variation of Model Conditions at Point 1 Upstream of the Discharge Point Over a Two Month

Period (Dry Season Conditions) ..................................................................................................... 54 Figure 5 Model Concentration of Total Nitrogen (Top) and Total Phosphorus (Bottom) for Dry Season

Conditions ...................................................................................................................................... 54 Figure 6 Additional Discharge Interpretations............................................................................................. 55 Figure 7 Riparian Buffers ............................................................................................................................. 66 Figure 8 Areas of Potential High Water Level Flow Connectivity ................................................................ 73 Figure 9 Power Facility and Incinerator Location ........................................................................................ 82

LIST OF PLATES Plate 1 Rocky Outcrop and Intertidal Bed Material at Point Ceylon (Water Technology 2015) ................ 68

LIST OF APPENDICES

Appendix 1

Appendix 2

Updated Chapter 11

Updated Draft EMP


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ABBREVIATIONS AND ACRONYMS

Acronym or Abbreviation

ANZECC & ARMCANZ Australian and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand

ASC Aquaculture Stewardship Council

AWQG Australian Water Quality Guidelines

BMC Broodstock Maturation Centre

CBC Core Breeding Centre

draft EIS Core Breeding Centre and Broodstock Maturation Centre Draft Environmental Impact Statement

DENR Department of Environment and Natural Resources

EA Act Northern Territory Environmental Assessment Act

EIS Environmental Impact Statement

EMP Environmental Management Plan

EPBC Act Commonwealth Environment Protection and Biodiversity Conservation Act 1999

ha hectares

km kilometres

m3 cubic metres

mg/L milligrams per litre

NOI Notice of Intent

NT Northern Territory

NT EPA Northern Territory Environmental Protection Authority

PL post larvae

PV photovoltaic

Seafarms Seafarms Group Limited

SEIS or supplementary EIS Stage 1 Legune Grow-out Facility Supplementary Environmental Impact Statement

the Project Core Breeding Centre and Broodstock Maturation Centre

the proponent Project Sea Dragon Pty Ltd

TN total nitrogen


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Acronym or Abbreviation

ToR Terms of Reference for the Preparation of Environmental Impact Statement

TP total phosphorus

TSS total suspended solids

WA Western Australia


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1 INTRODUCTION

1.1 PURPOSE OF THIS DOCUMENT Project Sea Dragon Pty Ltd (the proponent) is proposing to develop the Core Breeding Centre and Broodstock Maturation Centre at Bynoe Harbour in the Northern Territory. A draft Environmental Impact Statement (draft EIS) was prepared for the Project and was placed on public exhibition from Friday 11 November to Friday 9 December 2016. Stakeholders were provided with the opportunity to make submissions on the draft EIS during this period.

Following the public comment period, on 15 December, 2016 the Northern Territory Environmental Protection Authority (NT EPA) directed the proponent to prepare a supplement to the draft EIS. Accordingly, this document has been prepared and is herein referred to as the supplementary EIS or SEIS. The SEIS summarises and addresses the comments received on the draft EIS during the public comment period.

Additionally, the SEIS includes an updated version of the draft Environmental Management Plan (EMP) (see Appendix B). As stated in Section 1.1 of Appendix 19 (draft EMP) of the draft EIS, the draft EMP will be updated to reflect approval requirements upon approval of the Project. In keeping with this commitment, the draft EMP has been amended to incorporate updates that occurred following the lodgement of the draft EIS. These updates are reflected in the responses presented in this SEIS (for example, inclusion of provision of actions to be taken in the event of unexpected cultural heritage findings - see Section 3.8.2 of this document).

The draft EIS and the SEIS, collectively referred to as the EIS, is intended to be the proponents final submission to the NT EPA as part of the environmental approvals process under the Northern Territory Environmental Assessment Act (EA Act).

1.2 STRUCTURE OF THIS DOCUMENT The SEIS contains the following information:

Section 1 describes the purpose of the document, a brief Project overview and a summary of the assessment process to date.

Section 2 provides a summary of the submissions received on the draft EIS during the public comment period.

Section 3 presents each of the comments received from submitters during the public comment period and corresponding responses from the proponent.

Section 4 is a summary of references cited.

Appendices provide additional information referred to in the responses.

1.3 PROJECT OVERVIEW

1.3.1 Project Sea Dragon The proponent, a wholly owned subsidiary of Seafarms Group Limited (Seafarms) (ASX: SFG), proposes to develop Project Sea Dragon, a large-scale, integrated, land-based prawn aquaculture project in northern Australia. Project Sea Dragon is designed to produce high-quality, year-round reliable volumes for export markets for black tiger prawns (Penaeus monodon).


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Project Sea Dragon is a staged development of up to 10,000 hectares (ha) of production ponds, comprising a number of facilities across northern Australia (Figure 1), including:

The Grow-out Facility - proposed to be located at Legune Station in the NT.

Quarantine, Founder Stock Facility and Back-up Breeding Centre - located at Exmouth in Western Australia (WA).

Breeding Program (Core Breeding Centre and Broodstock Maturation Centre) - proposed to be located at Point Ceylon at Bynoe Harbour, NT.

Hatchery Site - proposed to be located in the Darwin environs, NT.

A Processing Plant - proposed to be located near Kununurra, WA.

Export Facilities – proposed to be located at either or both Wyndham, WA and Darwin, NT.

The Core Breeding Centre and Broodstock Maturation Centre (herein referred to as the CBC and BMC or the Project) is a component of the larger Project Sea Dragon.

1.3.2 Core Breeding Centre and Broodstock Maturation Centre The CBC will be used for the genetic development, production and selection of high performing Specific Pathogen Free prawns. The prawns for the CBC will be sourced from the Founder Stock Facility in Exmouth. At the CBC, families of prawns will be raised to avoid unmanaged cross-breeding, and to maintain genetic lineages. The top individual performers within the top families will be used to supply the BMC and produce commercial broodstock. At full scale production, the CBC will have capacity for up to 400 families1 of unrelated genetic signatures.

The BMC will be used to grow and mature the selected post larvae (PLs) and larger broodstock supplied from the CBC. The young broodstock entering the BMC from the CBC will be Specific Pathogen Free, in good health and brought up to a suitable size and condition for breeding. The BMC will be responsible for the production of commercial numbers of spawners and their mates for the commercial hatchery, which is to be located within the Darwin environs.

The CBC and BMC will be fully biosecure and managed in accordance with the requirements of the Project Sea Dragon Biosecurity Manual.

1 A family is a related group of animals with a traceable and controlled pedigree, and degree of relatedness.


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FIGURE 1 PROJECT SEA DRAGON COMPONENT LOCATIONS


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1.4 SUMMARY OF THE ASSESSMENT PROCESS A Notice of Intent (NOI) for the Project was submitted to the NT EPA on 19 February 2016 for consideration under the EA Act. Following submission of the NOI, the proponent responded to a number of requests for information from the NT EPA. These requests for information related to waste discharge options and further interrogation and clarification of the waste water modelling.

On 19 August 2016, the NT EPA decided that the Project required assessment under the EA Act at the level of an EIS. The NT EPA decision was based on the following issues:

potential impacts from the discharge of waste from the prawn farming activities into receiving waters considered to be of high environmental value

the management requirements for solid and liquid waste and the potential detrimental effects of inappropriate management practices

potential impacts and risks associated with securing an adequate fresh water supply for the site and

public interest.

In the Statement of Reasons explaining the NT EPA's justification for the Project being assessed at the level of an EIS, the NT EPA stated the following in relation to potential impacts on the marine environment:

"The NT EPA is satisfied that the potential impacts and risks associated with installation of the seawater intake pipe are unlikely to be significant and can be adequately managed through the implementation of measures proposed in the NOI. In relation to the release point, there is potential for acid sulfate soils to be disturbed in a limited area but impacts are likely to be localised and minimal if such material is managed appropriately

The NT EPA considers that the interim water quality guidelines / values provide a reasonable basis for assessment of potential impacts until the guidelines values can be refined

The impacts from the release of discharge water are likely to be localised and should not extend into the wider harbour and

The NT EPA considers the proposed release of discharge water to Wheatley Creek is not likely to significantly affect the regional water quality of Bynoe Harbour in the long term, though there may be some localised, longer term enrichment near the point of discharge in Wheatley Creek."

Furthermore, in relation to erosion and sediment control, acid sulfate soils (ASS), biting insects and weeds, the NT EPA stated that "potential impacts and risks associated with erosion and sediment control, acid sulfate soils, biting insects and weeds can be adequately managed through the implementation of standard measures".

As such the ‘Terms of Reference for the Preparation of Environmental Impact Statement’ (ToR) issued by the NT EPA was focussed on the specific issues around the discharge of water into the receiving environment, waste management requirements for solid and liquid wastes, freshwater supply and public interest in the Project..

The Project was also referred to the Australian Government under the EPBC Act on 27 May 2016. On 13 September 2016, a delegate of the Commonwealth Minister for the Environment decided that the proposed action was not a controlled action and, as such, did not required assessment and approval under the EPBC Act.

The draft EIS was submitted to the NT EPA on 7 November 2016 and was made available for public comment from 11 November to 9 December 2016. On 15 December 2016 the NT EPA directed the proponent to prepare


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a supplement to the draft EIS. Accordingly the SEIS was prepared and was submitted to the NT EPA on 10 February 2017.

The NT EPA Environmental Assessment Unit has 35 days from the submission of the SEIS to prepare a draft assessment report and recommendations for consideration by the NT EPA. The assessment report will then be provided by the NT EPA Minister to the responsible Minister (i.e. the Minister of the Department of Primary Industry and Fisheries) for consideration and final determination as to whether or not an approval will be issued, and if so, the conditions that may be applied.


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2 SUMMARY OF SUBMISSIONS

Following the public comment period the proponent received 17 separate submissions on the draft EIS. As summarised in Table 1, 12 of the 17 submissions received were from Northern Territory Government Departments.

Six of the submissions were in support of the Project and required no further response by the proponent. Comments from these submitters included the following:

Department of Primary Industry and Resources (see Section 3.7):

"The draft EIS, as presented, comprises a comprehensive set of documents that adequately identifies and addresses the risks posed by this component of the Project Sea Dragon prawn farming developments.

The Department of Primary Industry and Resources acknowledges the substantial economic benefit that Project Sea Dragon represents, not only to the Northern Territory, but to the Australian economy.

The scale of this aquaculture project is without parallel in Australia and its successful delivery will have long-standing and far-reaching value for Territory, and especially for regional communities."

Department of Tourism and Culture - Heritage Branch (see Section 3.8):

"The Heritage Branch is satisfied that cultural heritage issues and potential risks have been adequately assessed and suitable control measures incorporated into the Draft Environmental Management Plan."

Department of Trade, Business and Innovation (see Section 3.11):

"The Department of Trade, Business and Innovation (DTBI) does not have any major issues with the project's draft EIS.

….

The EIS provides valuable information on employment and business opportunities in the construction and the operational phases of the Centres accruing to the Territory including the local region in which the Centres are located."

The University of Technology Sydney provided support for the draft EIS stating that the proponent "should be commended for their well-presented and considered Environmental Impact Statement" (Section 3.17)

TABLE 1 NUMBER OF SUBMISSIONS RECEIVED FROM STAKEHOLDERS

Stakeholder Number of Submissions Received

Northern Territory Government Departments 12

Northern Territory Government Owned Corporation 1

Educational Institutions 1

Private Individuals 2

Community Environment Group 1


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Table 2 presents a summary of the number of comments received from each submitter, with a total of 118 comments received. The majority of the comments received were from the NT EPA (36 of 118), followed by the Commonwealth Department of Environment and Energy (24 of 118).

TABLE 2 NUMBER OF COMMENTS RECEIVED FROM EACH SUBMITTER

Submitter Number of Comments Received

Department of Attorney-General and Justice - NT Worksafe 5

Department of Chief Minister 4

Department of Environment and Natural Resources 24

Department of Health - Environmental Health Branch 3

Department of Health - Medical Entomology 1

Department of Infrastructure, Planning and Logistics 6

Department of Primary Industry and Resources 1

Department of Tourism and Culture - Heritage Branch 2

Department of Tourism and Culture - Parks and Wildlife 1

Department of Tourism and Culture - Tourism NT 2

Department of Trade, Business and Innovation 1

Environment Centre 9

Ian and Pat Stuart 7

NT EPA 36

Power and Water Corporation 1

R. A. White 12

University of Technology Sydney 3

Figure 2 presents a breakdown of the key issues that were raised during the public comment period. Over 45% of the comments received related to the following three matters:

project description

marine and estuarine water

marine and estuarine ecology.


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FIGURE 2 SUMMARY OF ISSUES RAISED DURING THE PUBLIC COMMENT PERIOD

0 5 10 15 20 25

Biting InsectsCultural Heritage

GroundwaterHealth and Safety

NoiseSoils

FreshwaterAir QualityBiosecurity

Ecologically Sustainable DevelopmentUnrelated to Project/EIS

Socio-economicSupport for Draft EIS/Project

Traffic and TransportWaste Management

Approvals, Conditions and OutputsTerrestrial Flora and Fauna

Marine and Estuarine EcologyMarine and Estuarine Water

Project Description

Number of Submissions


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3 RESPONSE TO SUBMISSIONS

3.1 DEPARTMENT OF THE ATTORNEY-GENERAL AND JUSTICE - NT WORKSAFE

3.1.1 Comment 1 Submitter Type NT Government TOR Category or EIS

Chapter -

Date Submission Received

8 December 2016 Submitters Reference to EIS Section (if provided)

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Details of the Submission

NTWS recognises that risk assessment process was undertaken for the Biophysical aspects of the operations. Further safety risk assessments will be required as the project progresses.

Proponent Response

Noted. The Terms of Reference for the Project focussed on a number of specific issues around the discharge of water into the receiving environment, waste management requirements for solid and liquid wastes, freshwater supply and public interest in the Project. The NT EPA considered that other risks identified in the NOI were not significant and could be dealt with through the proponent's management plans. As such, health and safety risks will be dealt with in a health and safety plan which will be developed as part of the Project. This will include a further health and safety risk assessment.


Chapter Approval, Conditions and Outputs



Section 4, Table 4.3


Table 4.3 lists the applicable legislation however neglects the following which have direct relevance:

1. Work Health and Safety (National Uniform Legislation) Act

2. Electricity Reform Act

3. The Transport of Dangerous Goods by Road and Rail (National Uniform Legislation) Act may also beapplicable for the transporting of chemicals to and from the project site.

Proponent Response

The legislation listed in Table 4.3 of the Project Overview is limited to the acts that falls under the auspices of the EIS. There are a number of other acts including the Work Health and Safety (National Uniform Legislation) Act and Electricity Reform Act which may be applicable to the Project. These acts have not, however, been addressed in the EIS as they do not relate directly to the Terms of Reference for the Project.

The Transport of Dangerous Goods by Road and Rail (National Uniform Legislation) Act is relevant in terms of implementing the Australian Dangerous Good Code, and has been added to an updated version of the Environmental Management Plan, in Appendix C9.


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Chapter Approval, Conditions and Outputs



Section 4.4.3, Pg 4-67


Section 4.4.3 (page 4-67) describes the Dangerous Goods Act. This reference is incorrect for the transport and handling of dangerous goods. This is handled via #3 above.

Proponent Response

Noted. No response.


Chapter Chemical Inventory



Appendix 8


Appendix 8 deals with chemical management much of which is based on Queensland requirements. The proponent must review this to ensure Northern Territory requirements are complied with (i.e. Appendix 8 Page 5).

Proponent Response

The chemical inventory and safe work instruction reference provided in Appendix 8 is for the proponent's Flying-fish Point Hatchery operations in Queensland. This was provided as a reference as the same chemicals used at the Flying-fish Pont Hatchery will be utilised at the CBC and BMC. A site specific chemical inventory and safe work instruction reference will prepared for the CBC and BMC and will include relevant requirements under Northern Territory legislation.


Chapter Chemical Inventory



Appendix 8


The proponent should ensure an understanding of the above legislation to ensure they have a thorough understanding of their duties and obligations.

Proponent Response

Noted. The proponent will ensure that they have a thorough understanding of their duties and obligations under all relevant legislation.


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3.2 DEPARTMENT OF CHIEF MINISTER


Chapter Project Description



Chapter 3


Project Sea Dragon has major project status from the NT Government and offers potential significant economic benefits to the Northern Territory in terms of income, jobs and business opportunities for local suppliers. As the Point Ceylon project is one of the central elements to the success of Project Sea Dragon, it is important that this project’s approvals, recommendations and conditions align with the other elements of the project – specifically Legune Station.

The proponent proposes to use diesel as the preferred energy source for the project noting it is economical, readily available, easily sourced and has sufficient workforce for maintenance of diesel generators in the area. Whilst DCM appreciates the power requirement of this site is significantly less than Legune Station, the Proponent proposes to use a hybrid power generation plant (diesel and solar PV) at Legune Station. The NT Government has recently announced a target of 50% renewable energy and given the proposed lifespan of this project, DCM would like to see further consideration given to the use of solar PV in addition to diesel generators at Point Ceylon to better align with the Northern Territory’s policy for renewable energy. DCM notes the Proponents comments in Chapter 3 concerning alternative energy options and the comment in regards to land clearing requirements in order to have the space for the installation of solar. Given the Proponent will source solar PV for Legune, the additional purchase for Point Ceylon could be economical managed and would reduce ongoing diesel costs for the project.

Proponent Response

The situation at Bynoe Harbour is not comparable to grow-out facility at Legune for a number of reasons including, for example: scale of project, terrain and vegetation cover and type, power requirements, and logistics including haulage distances. The proponent examined feasibility and cost of grid connection and concluded after investigation that an off-grid solution was necessary.

As power demand is required for the facility 24 hours per day, renewables were not considered to be economically or environmentally optimal. The footprint to include photovoltaics would be extensive requiring a much larger area for land clearing in addition to the installation of diesel for power back-up and potentially battery storage. Thus the on-site environmental impacts are likely to outweigh the benefits of renewables in this instance.

The proponent also took into account risks and other potential impacts, such as timing implications, for the larger, overall requirements of Project Sea Dragon. The costs (including reliability considerations) of PV and renewable/hybrid solutions also far outweigh the solution proposed for assessment such that the conclusion from the proponent's investigation does not indicate that inclusion of renewable solutions can be economically managed.

The proponent will review power requirements towards the end of asset lifecycle and when and if there are better economic and technical solutions.


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DCM notes that Proponent has yet to determine the method for disposal of biological waste (incinerated onsite or frozen and disposal to Shoal Bay through a licenced contractor). DCM would expect that this information will be finalised and provided in detail within the supplement.

Proponent Response

As discussed in Section 12.4.5 of the draft EIS, the proponent has considered both incineration and off-site disposal through a licenced contractor for the disposal of biological waste. Both methods are considered to be feasible solutions and the proponent will determine the preferred method following detailed design. All relevant approvals for preferred method of the disposal will be obtained prior to operations.


Chapter Socio-economic



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The draft EIS addresses social impacts. DCM appreciates the Proponents efforts to consult with the community and stakeholders. DCM also notes and appreciates the Proponent’s intention to undertake twice-yearly community information and consultation sessions during operations to address, wherever possible, emerging socio-economic issues. DCM’s Social Policy workgroup welcomes the opportunity to work with Seafarms on the development and implementation of a social impact management plan, including the development of a short-term accommodation strategy which measures and manages the impacts on local services.

Proponent Response

Noted. As discussed in Section 14.5 of the draft EIS, the social impact management plan will be developed prior to construction of the Project. The proponent will work with the Department of the Chief Minister Social Policy workgroup during the development of this social impact management plan.





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DCM notes the impact from waste water is a primary risk for the project. DCM is aware that the Proponent continues to collect water samples for Bynoe Harbour and the receiving waters in close proximity to the proposed discharge area. DCM anticipates that the Proponent will continue to share water data with the


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relevant authorities as it comes available, continue to adequately monitor the projects surrounding waters and abide by all issued waste water licence requirement and project approval conditions.

Proponent Response

Noted. As detailed in Section 11.7 of the draft EIS, the proponent commits to undertaking a water quality monitoring program to monitor the impact of the Project on the receiving environment and confirm adherence to all discharge license criteria. Water quality data is currently being and will continue to be collected until there is at least 12 months pre-construction baseline data. This will allow site specific trigger values to be determined for the site in accordance with the Australian and New Zealand Guidelines for fresh and marine water quality (Australian and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand [ANZECC & ARMCANZ] 2000), often referred to as the Australian Water Quality Guidelines (AWQG). The impact of the Project on the receiving environment will then be monitored against these trigger values. The results of all monitoring undertaken will provided to the relevant authorities.

3.3 DEPARTMENT ENVIRONMENT AND NATURAL RESOURCES


Chapter Other



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The proponent has generally addressed the Terms of Reference. Although Seafarms concludes that it is highly unlikely that the proposed project will pose a significant impact to any threatened or migratory species or habitats, some risks remain unresolved due to insufficient data to the extent that some impacts cannot be fully assessed or managed appropriately. These particularly relate to potential issues around water quality, particularly at the discharge point with its accompanying risks to benthic habitats and fauna. These issues are discussed further below.

Proponent Response

Noted. These points are addressed in response to specific comments listed below.


Chapter Marine and Estuarine Water



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The draft EIS states that modelling demonstrates that water quality changes from the outfall discharge will be minimal in the broader marine environment, outside a localised mixing zone. Nutrient levels will be elevated in the mixing zone 100 metres either side of the outlet.

Figure A-8 in the Water Technology report compares modelled and measured current speeds. The output suggests the modelled current speed is faster (e.g. 0.10 m/s) than the measured current speed, which may lead


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to inaccurately modelled nutrient flushing and retention rates. The longer term fate of nutrient discharge at Wheatley Creek has not been established as the model is limited to a tidal cycle.

Proponent Response

The hydrodynamic model has been calibrated to measured water levels over a week long period and validated against tides measured during the calibration period. Modelling of discharge from the facility has also been simulated for a 12-month period not 'a tidal cycle' as stated by the submitter.

In terms of the model itself, it is considered to match well with predicted and measured water levels. The model falls within guidelines published by the United Kingdom Environment Agency (1998), which provide performance requirements for numerical hydrodynamic models in estuaries and coastal areas and are considered appropriate for use in the Australian context. Table 3 gives the guidelines and an explanation of how the EIS model complies with those guidelines.

TABLE 3 PERFORMANCE REQUIREMENTS FOR NUMERICAL HYDRODYNAMIC MODELS IN ESTUARIES AND COASTAL AREAS (UNITED KINGDOM ENVIRONMENT AGENCY 1998)

Parameter Guidelines EIS Model

Coastal areas Estuaries

Water levels +/- 0.1 m or within 10% of spring tide range or 15% of neap tide range

+/- 0.1 m at the mouth or +/-0.3 m at the head; or within 15% of spring tide range or 20% of neap tide range

Modelled water levels are within 5% of measured or predicted spring tide and neap tide water levels

Current speeds +/- 0.1 m/s or within 10-20% of observed speeds

+/- 0.2 m/s or within 10-20% of observed speeds

Modelled current speeds are within 0.05 m/s of observed data within the lower Wheatley Creek (Figure A-7 in Water Technology report [Appendix 17 of draft EIS]) reach and within 0.2 m/s of observed data at the upstream (head) of the estuary (Figure A-8 in Water Technology report [Appendix 17 of draft EIS])

Current direction +/- 10 degrees +/- 20 degrees Within Bynoe Harbour, modelled current directions are within 16 degrees of astronomic currents


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Interim conditions for the water quality licence have been provided with the intent of refining these as more data become available. Monitoring the effects of discharges on the local marine environment is challenging as changes detected in water quality parameters may not necessarily reflect changes or impacts to ecological processes. The standard concentrations used to measure water quality are only proxies for ecological processes as these concentrations can be highly variable (e.g. Burford et al. 2003). Monitoring key processes such as primary production rates, phytoplankton responses to nutrients, community shifts in zooplankton and fish grazing patterns, and elevated N ratios in marine plants, would be more suitable ways to detect water quality changes.

Proponent Response

The proponent will prepare and implement a water quality monitoring program for the Project as a requirement of their waste discharge licence. As part of the monitoring program, the proponent commits to the collection of data regarding macroinvertebrates and δ15N signatures from mangroves. Macroinvertebrates are commonly used as an indicator of environmental quality and δ15N signatures integrates water quality data over time and provides a direct indication of whether the discharge is impacting the receiving environment. Samples will be collected prior to construction to ensure that baseline data is established. Monitoring of sediment quality will also be conducted, another line of evidence related to long term water quality changes.

The proponent agrees that water quality monitoring is a proxy for assessing potential impacts to ecological processes, which is precisely why it is proposed. Water Quality Monitoring typically provides a safer, quicker, simpler and cheaper approach and can provide indicators and triggers for further investigation. Typically water quality monitoring represents a significant part of a broader ecosystem response monitoring program including the above, non-water quality measures. This is a common and highly suitable approach to ecosystem health monitoring, well established in Australia in all jurisdictions under the National Water Quality Management Strategy. Water monitoring and the aforementioned measures of ecosystem processes will complement each other in determining water quality changes and potential impacts on ecosystem processes.


Chapter Marine and Estuarine Ecology



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The EIS describes the marine habitat broadly within Bynoe Harbour, identifying seagrass habitat approximately 200 km away with some patchy seagrass close to Point Ceylon. Sponges and soft corals dominate the reef benthos of Bynoe Harbour, together with hard corals of the genus Turbinaria (Smit et al. 2000). Sub-tidal habitats have not been discussed or mapped in the EIS. The EIS refers to a “Section 0” where the environmental values of Wheatley Creek are described; however, this section has not been provided. If


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requested, DENR can provide benthic habitat data that identifies seagrass and other habitats of importance in the local region.

Proponent Response

The references to Section 0 in Chapter 11 are an editorial error in the document. The references to Section 0 have been updated and revised version of Chapter 11 is included as Appendix A. The section reference to the description of the environmental values of Wheatley Creek should have been to Section 9.3 of the EIS.

Benthic habitat and seagrass mapping of Bynoe Harbour has been obtained from the Department of Environment and Natural Resources and is shown in Figure 3. Based on this mapping, the benthic habitat within the immediate vicinity of the Project Area consists of intertidal areas. The closest seagrass beds are located 16 km from the Project Area, to the north of Indian Island (Figure 3).





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The EIS states that site selection for the proposal was based on known critical habitat. It is unclear how this was determined as no mapping of critical habitat has been included in the EIS. The characterisation of marine benthic habitat is limited and does not refer to relevant available data to provide a local context. For example the inclusion of data and information from R Chatto (wader~, sea~ and migratory birds), DENR (Seagrass), B. Glasby (sponges), and the Kenbi Land claim documentation would have better informed the description of the local environment, referencing the closest significant marine habitat and those which may be affected by the project.

Proponent Response

A number of studies were reviewed during the preparation of the NOI and EIS to characterise the marine environment surrounding the Project Area. Studies examined included those undertaken in Bynoe Harbour as well the wider region, including (but not limited to):

Brocklehurst, P. and Edmeades, B. (2003) Mangrove Survey of Bynoe Harbour Northern Territory. Department of Infrastructure Planning and Environment, Northern Territory. Palmerston.

Brooks, L. and Pollock, K. (2015) The Darwin dolphin monitoring program: abundance, apparent survival, movements and habitat use of Humpback, Bottlenose and Snubfin dolphins in the Darwin area. Report to INPEX, document number L384-AH-REP-10012_0

Cardno (2015a) Turtle and dugong monitoring post-dredging report: Ichthys Nearshore Environmental Monitoring Program. Report to INPEX, document number L384-AWREP-10250

Cardno (2015b) Seagrass monitoring post-dredging report: Ichthys Nearshore Environmental Monitoring Program. Report to INPEX, document number L384-AW-REP-10081

Chatto, R. and Baker, B. (2008). The distribution and status of marine turtle nesting in the Northern Territory. Technical Report No. 77, Parks and Wildlife Service of the Northern Territory.


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FIGURE 3 BENTHIC HABITAT AND SEAGRASS MAPPING OF BYNOE HARBOUR


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Chatto, R. and Warnecke, R.M. (2000). Records of cetacean strandings in the Northern Territory of Australia. The Beagle 16: 163-175.

Department of Land and Resource Management (2015) Department of Land Resource Management – NT Fauna Observations. Viewed online 1 December 2015 at http://www.lrm.nt.gov.au/plants-and-animals/informationand-publications/nt-fauna-observations

EcOz (2003) Point Ceylon Aquaculture Project. Point Ceylon, Bynoe Harbour, Northern Territory Environmental Risk Assessment. Prepared for Suntay Aquaculture.

Roelofs, A., Coles, R., and Smit, N. (2005) A survey of intertidal seagrass from Van Dieman Gulf to Castlereagh Bay, Northern Territory, and from Gove to Horn Island, Queensland. Report to the National Oceans Office, Department of Environment and Heritage.

Smit, N., Billyard, R. and Ferns, L. (2000) Beagle Gulf Benthic Survey: Characterisation of soft substrates. Technical Report No. 66, Parks and Wildlife Commission of the Northern Territory.

Water Technology (2015) Point Ceylon coastal environment and hydrodynamics assessment. November 2015.

Further to the aforementioned studies that were reviewed for the EIS, the studies referred to in DENR's submission were reviewed as part of this supplementary EIS. The main findings of these studies in relation to the Project are summarised below.

Surveys of Bynoe Harbour and Darwin Harbour undertaken by Chatto (2003, 2006) recorded shorebirds and waterbirds around most of the coastline. The highest densities of shorebirds and waterbirds however, were recorded in the islands off Bynoe Harbour (most notably on Bare Sand Island) and on the coast to the east of Darwin. Bare Sand Island is located 24 km to the north-west of the Project Area.

A survey of sponges undertaken by Alvarez and Hooper (2009) identified a number of different sponge species present in Bynoe Harbour. These were collected from a number of different locations in Bynoe Harbour, with the closest records being from Dawson Rock, approximately 2 km to the north-east of the Project Area.

Seagrass mapping undertaken by DENR in Bynoe Harbour indicates that the closest seagrass beds are located 16 km from the Project Area, to the north of Indian Island (Figure 3).

Areas of significant marine habitat identified by these studies are located well away from the Project Area and therefore would not be impacted by the Project. As such, this additional information does not change the findings of the EIS.





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The proposed intake pipeline for the Project is to be installed at approximately 10 metres depth within Bynoe Harbour in an area suggested in the draft EIS to be characterised by sand/gravel substrate and associated benthic fauna. No physical habitat assessment data is provided to substantiate this. While the proponent

http://www.lrm.nt.gov.au/plants-and-animals/informationand-publications/nt-fauna-observations



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expects the benthic habitats to recover once the infrastructure has been installed, the validity of this remains unknown until the habitat has been characterised. Some communities (e.g. coral-dominated communities) also have a limited ability to recover.

Proponent Response

Physical habitat surveys of Bynoe Harbour were not required as part of the Terms of Reference for the Project. Furthermore, the NT EPA noted in their submission of the EIS that they did not consider it necessary to conduct a physical habitat survey of Bynoe Harbour.

Despite this, further habitat characterisation using existing data sources has been undertaken in response to Comment 16 from the NT EPA (see Section 3.14.16).





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Benthic habitat characterisation is also used to assess the risk to EPBC-listed threatened, migratory and marine megafauna (e.g. pipefish, seahorses, Dugong, turtles) in Table 2. The logic presented is that no further assessment is required for these species as their habitats are not present and therefore these species are unlikely to occur in the project area. However, insufficient marine habitat assessment has been undertaken and/or insufficient data is presented in the EIS to robustly support this conclusion.

Overall, the values of local benthic habitats and the risks to these have not been adequately evaluated in the draft EIS to the level of detail required in the Terms of Reference.

Proponent Response

Further habitat characterisation and assessment of the risks posed to threatened and migratory megafauna has been undertaken in response to Comment 16 from the NT EPA (see Section 3.14.16)





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Marine fauna values have been determined through multiple sources of survey data and inferred from limited habitat data. This area is recognised as having significant populations of EPBC-listed marine turtles, dugong and coastal dolphins. There have been no specific surveys to determine marine fauna values at the scale of the project or inferred through project–scale marine habitat surveys.

Proponent Response

It was not a requirement of the Terms of Reference to undertake marine fauna or physical habitat surveys of Bynoe Harbour.


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As discussed in Section 9.3.2 and in response to Comment 5 from DENR (Section 3.3.5), a number of marine megafauna and other environmental monitoring surveys have been undertaken across Darwin Harbour and Bynoe Harbour. This information has been reviewed and used as the basis for assessing potential impacts to threatened and migratory marine megafauna from the Project.





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This project may potentially impact marine fauna both directly and indirectly. The EIS describes marine megafauna (turtles, dugongs, dolphins, sea snakes and crocodiles) as transient species that are likely to be temporarily displaced, suggesting if they are impacted, they are likely to be return once these impacts cease. This suggestion is in conflict with the observed behaviours of at least turtles and dugongs where high site-fidelity to habitats of importance has continued despite the habitat being degraded (e.g. large-scale habitat loss, vessel strike, lighting impacts). In some instances this has resulted in declined health and/or increased mortality (Preen and Marsh 1995, Hazel and Gyuris 2006, Meager and Limpus 2012, Kamrowski et al. 2014, Meager and Limpus 2014).

Proponent Response

Marine megafauna such as marine turtles, fish, dolphin, dugong, sea snakes and crocodiles are transient species. High site-fidelity to habitats of importance has been observed, but it is important to note that the marine areas to be affected by the proposed Project do not represent habitats of high importance to marine megafauna (e.g. nesting areas, seagrass, coral). Moreover, impacts from the construction and operation of the Project will be localised and will only affect a small area surrounding the intake and discharge locations, and that these

The NT EPA in their Statement of Reasons stated that impacts on marine megafauna from the construction of the Project could be adequately managed through the implementation of measures proposed in the NOI. Furthermore they also stated that any impacts from that waste water discharge during operations was unlikely to be measurable in Bynoe Harbour and therefore not likely to affect ecologically significant areas for marine megafauna.

During construction, minor sediment disturbance will occur and will temporarily influence the water quality at the seabed adjacent the footprint. This disturbance will be localised, short term and temporary in nature. As mentioned previously, the species that may be influenced by these disturbances are highly mobile and are expected to move away from disturbance areas such that they are not detrimentally affected. They are also expected to return to the area following cessation of disturbances; this is supported by evidence collected under the Ichthys nearshore environmental monitoring program (Cardno 2015a, b) for a large scale dredging and pile driving program in the Darwin region. Monitoring results found no indication that dredging activities affected turtle distribution or population sizes (Cardno 2015a).

The results of the numerical modelling (Section 5.1.7 of the draft EIS) investigating the impacts of the operational discharge on the marine environment revealed that, outside of the initial mixing zone (which will extend for approximately 100 m upstream and downstream of the proposed discharge location), the interim water quality objectives that have been defined for the project are unlikely to be exceeded. As such it is not


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predicted that the operational discharge will detrimentally affect water quality such that habitat, feeding resources or health of fish or turtle species would be affected.

If marine megafauna do transit the discharge point during discharging activities, the most likely impacts would be behavioural impacts (e.g. swimming away from the area). Any behavioural impact caused by a reduction in water quality is likely to be localised and temporary, with marine species expected to resume normal behavioural patterns in the waters surrounding the project area in a short time-frame. Given the spatial disconnect between the discharge locale and the areas known to be utilised by marine megafauna, impacts from discharge are expected to be minimal.

Other water quality related operational risks such as the unplanned accidental release of cleaning chemicals are considered a very low risk and will be controlled via operational procedures and environmental management plans required to detect and respond to any unplanned accidental releases to ameliorate impact to the environment.

Management controls for unplanned construction inputs from land-based erosion (including during extreme weather events) have been nominated in the draft EMP, the updated version of which can be found at Appendix B of this SEIS.





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The EIS reports marine turtle nesting approximately 15 km from the project site on Indian Island (Chatto and Baker 2008). There are other beaches on Indian Island closer to Ceylon Point (within 3 km) which may also have nesting habitat for marine turtles. The absence or presence of turtles nesting on these other beaches should be validated, and appropriate mitigation developed if present. The impacts of artificial lighting on hatchling turtles have generally been identified and appropriately mitigated in the EIS.

Proponent Response

Nesting beaches are absent from the project footprint and immediate surrounds as the intertidal and foreshore areas are characterised by mangrove forests and soft sediments. The only known nesting beaches at the time of writing were at the northern end of Indian Island. The Project will not impact Indian Island and therefore the proponent does not consider it necessary to validate the absence or presence of turtles nesting on other beaches on Indian Island.





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The seawater intake pipe may entrain or impinge marine fauna and measures should be developed to mitigate this risk. Measures to mitigate impacts on marine species should include appropriate placement of the intake


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pipe, with the maximum velocity set within the speed of tidal movements so that most marine species can swim against the current and avoid the intake point, and restricting intake to the mid to high tide period. The mesh on the intake pump should be sized to prevent hatchling Flatback or Olive Ridley Turtles, or other small threatened species (i.e. juvenile sawfish) potentially being entrapped. Implementing such measures will reduce risks to an acceptable level.

Proponent Response

As discussed in Section 9.3.2 of the draft EIS, the seawater intake point will be screened with mesh which will be appropriately sized to prevent hatchling turtles or juvenile sawfish becoming entrapped. Additionally the intake pump will only operate on the mid to high tide. This will avoid species in the vicinity of the intake during low tides and allow a 12 hour period each day when no fauna will be exposed to entrainment and impingement risks.





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The EIS identifies the potential risk of boat strike during the construction phase and endorses reporting boat strikes on marine megafauna or injured or stranded animals through the NT Government’s Marine WildWatch hotline or web portal. A speed limit of 5 knots should also be implemented for vessels operating in the waters in the project area during the construction phase to further reduce risk.

Proponent Response

Noted. A speed limit of 5 knots will be enforced for vessels working in the Project area during construction. This measure will be incorporated into the Environmental Management Plan for the Project.





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The EIS outlines the potential for piling to fasten the intake pipeline to the seabed if other methods are not viable. Marine pile driving can directly harm marine megafauna by temporarily or permanently shifting hearing thresholds, and indirectly by being displaced from potentially preferred habitat (Dahl et al. 2015). If pile-driving is necessary, then pre-determined exclusion zones should be monitored for marine megafauna. Pile-driving should be monitored and cease whilst marine megafauna are observed within the exclusion zone.

Proponent Response

Design of the Project has progressed such that the proponent is now able to rule out the potential for pile driving. No pile driving will be undertaken as part of the Project. The seawater intake pipeline will be secured by screw anchors or gravity anchors placed on the seabed. Screw anchoring is not synonymous with pile driving as there is a low noise level, and minimal vibration, associated with installation (screw piles are driven into the ground much as a screw is driven into wood).


25


Chapter Other



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To adequately resolve the level of residual risk to biodiversity values, it is recommended that further detail is provided on:

The potential to further reduce impacts from the discharge at the source, so as to remain within water quality guidelines and to minimise potential impacts on downstream values

Water quality modelling to better determine potential impacts to the receiving environment by incorporating different dilution scenarios, nutrient residence time and biological assimilation from site-specific data over a longer period, (such as 5 years)

Marine benthic environments within and adjacent to the pipeline footprint and in-take/discharge areas to adequately inform impact monitoring as per the Terms of Reference. Ideally this should include an assessment of marine in-fauna, to inform nitrogen uptake potential and the longer-term assimilation of elevated nutrients

A more robust monitoring program capable of detecting negative impacts to biodiversity values, Measures to mitigate impacts on marine species from the intake pipe, such as using an appropriate mesh size, a maximum intake velocity, and restricting intake to the mid to high tide period.

Proponent Response

To monitor any potential impacts from the waste water discharge on the receiving environment, the proponent will prepare and implement a water quality monitoring program. This water quality monitoring program will form part of the waste discharge licence for the Project and will include:

Determination of final specific trigger values based on 2 years of monthly data (24 data points), in accordance with the AWQGs.

Regular sampling of water quality in Wheatley Creek and Bynoe Harbour during operations. The proponent will consider sampling of additional sites in Wheatley Creek to better define the mixing zone.

Collection of sediment samples to assess potential impacts of the Project on sediment quality. Samples will be collected prior to construction to ensure that baseline data is established.

Collection of data regarding macroinvertebrates and δ15N signatures from mangroves to assess potential impacts to ecological values. Macroinvertebrates are commonly used as an indicator of environmental quality while δ15N signatures integrates water quality data over time and provides a direct indication of whether the discharge is impacting the receiving environment. Samples will be collected prior to construction and operation to ensure that baseline data is established.

The staged nature of the project will provide the opportunity to monitor and better understand the background water quality and associated biological processes in receiving waters within the earlier stages of release into Wheatley Creek. This will permit an adaptive approach to discharge water and subsequent release.


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Chapter Water Quality



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Recommendations outlined by the proponent to further minimise potential for water quality impacts are supported, including:

Timing the effluent discharge to support dilution and mixing in accordance with differing tides and water levels

Providing a diffuse discharge structure (such as the nominated weir) to increase initial mixing

Use of further water quality monitoring to validate existing site conditions and establish site-specific threshold criteria for management

Monitoring discharge to confirm that water quality guidelines/thresholds are not breached or to enable intervention.

Proponent Response

Noted. The proponent has committed to all of the above measures and will implement them as part of the Project.


Chapter Other



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Management of the ongoing discharge to waters of Wheatley Creek and nearby regional waterways presents one of the foremost impacts of the proposed operation. The Department supports the use of interim water quality guidelines and values as they present a reasonable basis for impacts where locally derived guidelines are yet to be determined.

Given the assimilative capacity of similar tidal creeks in nearby Darwin Harbour it is expected that the discharge would be constrained and not compromise the water quality of far-field areas such as Bynoe Harbour. However, the number of sites proposed as part of the water quality monitoring effort is not considered sufficient to capture spatial variation. The Department recommends additional near and far field sites to adequately understand the extent of mixing or influence.

It is recommended that ongoing monitoring effort at near and far-field sites continue providing valuable baseline data prior to the development and operation of the Core Breeding and Broodstock Maturation Centre.

Proponent Response

The proponent will prepare and implement a water quality monitoring program as part of their waste discharge licence under the Water Act. The water quality monitoring program will include the regular sampling of both near and far-field sites in Wheatley Creek and Bynoe Harbour. Consideration will be given to including


27

additional sites in the water quality sampling program in order to adequately assess the extent of the mixing zone. Ongoing monitoring at the sites outlined in the draft EIS has continued since lodgement of the draft EIS.





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Sediment quality in areas immediate to the discharge are likely to be at higher risk of enrichment. Monitoring effort should include a comprehensive sediment quality monitoring program to determine the extent of impact. Enrichment of sediments may hinder nutrient turn-over and a decoupling of important processes such as nitrification and denitrification. There is a lack of detail around the likelihood of chronic effects associated with continued discharge on sediment function and biota.

Proponent Response

As discussed in the response to Comment 16 (section 2.3.16), the proponent will prepare and implement a water quality monitoring program as part of their waste discharge licence, including sediment sampling. During the formulation of the monitoring program, the proponent will further consider the sediment sampling program to tailor it to enable assessment of potential impacts of the Project on sediment quality.





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It is important that the monitoring program is reviewed as the development reaches full operational capacity to ensure and licence conditions are maintained.

Proponent Response

As discussed in Section 2.5.4.3 of the draft EIS, the staged nature of the project will provide the opportunity to monitor and better understand the background water quality and associated biological processes in receiving waters within the earlier stages of release into Wheatley Creek. This will permit an adaptive management approach to discharge water and subsequent release.





Chapter 11, Pg 11-180


In regards to Part B: Page 11-180: The last paragraph refers to stream flows being 'concentrated during the wet season'. It is not clear what this refers to.


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Proponent Response

This statement was made in reference to the ephemeral freshwater streams which feed Wheatley Creek and an unnamed creek on the eastern side of the site. These streams only flow after significant rainfall events which predominately occur in the wet season. Hence the reference to stream flows being 'concentrated during the wet season'.





Chapter 11, Pg 11-230


In regards to Page 11-230: The Department supports the approach of timed discharge with tide to maximise flushing. Similarly retaining discharge waters for as long as feasible to enhance settling processes and mitigation of loads.

Natural variation is significant in this macro-tidal environment and it therefore imperative that data is interpreted with some context of tidal modulation, physico-chemical conditions and meteorological conditions.

Proponent Response

Noted. As detailed in Section 11.4.1 of the draft EIS, a baseline water quality sampling program has been undertaken. The purpose of the sampling program is to provide an insight into existing site conditions and to determine whether water quality is affected by any strong seasonal or event driven processes. This information will be used to develop baseline of water quality parameters so that site specific water quality guidelines and objectives may be determined.





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Surface water is sourced from outside. It needs to be noted that rainfalls would be of high intensity and short duration. It is presumed that the current drainages will cope with this with insignificant impact on the environment.

Proponent Response

The design has been undertaken with reference to standard stormwater design criteria, designed to protect human and environmental health and safety as a result of development. Minor drainage systems will be designed for the 2 year ARI storm event, with the major drainage being for the 100 year ARI event. Allowance will be made for suitably low depth and velocity, as well as and other safety considerations, as per applicable standards.


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Chapter Erosion and Sediment Control



Appendix C1 of the Draft EMP


It is acknowledged that an 'Erosion and Sediment Control Strategy' is provided at Appendix C1 of the Draft Environmental Management Plan (EMP) attached to the draft EIS, which describes the generic controls and management practices proposed. However, in order to ensure effective erosion and sediment control is achieved on ground, a site-specific detailed Erosion and Sediment Control Plan (ESCP) will be required.

Recommended Permit Condition:

Prior to the commencement of works, an Erosion and Sediment Control Plan (ESCP) should be developed in accordance with the IECA Best Practice Erosion and Sediment Control Guidelines 2008 www.austieca.com.au (or higher standard) by a suitably qualified and experienced professional in erosion and sediment control planning and subsequently reviewed and approved by a suitably qualified and experienced third party auditor. Evidence of the auditor's knowledge and experience in relation to erosion and sediment control planning, monitoring and management must be provided. The auditor should inspect works during construction and approve in writing that the works were undertaken on site in accordance with the approved plan. Furthermore, the auditor must approve in writing that the associated management and monitoring procedures and remedial actions (if required) are/were undertaken in accordance with the approved plan and effective. Details of any monitoring, sampling, site locations, laboratory results and actions by the developer should be provided. All works relating to this permit are to be undertaken in accordance with the endorsed ESCP to the requirements of the Consent Authority.

Proponent Response

The ESC Strategy in the draft EMP (Appendix C1) provides the specific framework for developing site specific ESCPs, namely:

'Prior to site works starting, detailed ESCPs will be prepared for all areas of ground disturbance. These are to detail the measures to be utilised, their locations, and any details required for their installation and maintenance. These will include:

an overview and key map of the entire development site, and specific maps for particular areas

location, area and boundaries of vegetation clearing and other disturbance areas on the site, and no go areas on the site (no clearing, or no access or both)

the location of any significant features, waterways and natural drainage features

natural contours and identification of any high risk erosion areas

erosion and sediment controls, including type, location and any other particulars required'

In terms of design standards, the ESC Strategy also requires that 'All erosion and sediment controls to be installed and operated according to concepts in IECA (2008) and DNREAS (2010), and this management strategy'. All personnel are to be appropriately experienced and qualified for their various roles in the Project, including ESC design and implementation, as required under the Project wide EMS.


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In terms of a third party auditor, Seafarms will utilise an appropriately qualified and experienced person to design the ESCPs, and will submit these to DLRM for review. An external environmental scientist/engineer will be engaged to provide external inspections and review of the site environmental management system, including monitoring. Detailed ESCPs will include detail on monitoring, regular site audits, and inspections, and requirements for written reports confirming that these controls have been installed as per the plans. The updated of the draft EMP can be found at Appendix B of this SEIS.


Chapter Acid Sulfate Soils



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Comments have been provided previously in relation to the occurrence of acid sulfate soils in the tidal areas associated with the development proposal. Field investigations are currently being undertaken as part of geo-technical surveys which will presumably provide the basis for an Acid Sulfate Soil Management Plan. There is already an understanding that the potential risk associated with acid sulfate soils can be adequately managed through the implementation of standard measures by the proponent. The proponent has committed to preparing and implementing detailed management plans for potential impacts of the project.

Proponent Response

Noted and agreed. The Acid Sulfate Soil Management Strategy in the draft EMP (Appendix C3) outlines the proposed approach. The updated version of the draft EMP can be found at Appendix B of this SEIS.


Chapter Acid Sulfate Soils



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Previous comments made in relation to weed management are still considered to be relevant (DLRM2016/0129, 30 March 2016).

Proponent Response

The proponent did not receive these comments and is therefore unable to provide a response. However, it is assumed that these comments were provided to the NT EPA with reference to the Notice of Intent. As such the NT EPA will likely have considered these comments during formulation of the Terms of Reference for the Environmental Impact Assessment for the Project.


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3.4 DEPARTMENT OF HEALTH - ENVIRONMENTAL HEALTH BRANCH





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It is noted that onsite accommodation will be provided including a manager’s residence and 2 eight bed dormitories. It is unclear whether a mess will be provided as part of the onsite facilities. Should food be prepared on site and supplied to staff the commercial food preparation area would be considered a food business and require registration with the Environmental Health Branch in accordance with the Food Act.

Proponent Response

There will be no mess or food preparation areas. All meals for the staff, with the exception of the manager, will be prepared at the offsite accommodation, which is proposed to be at the existing Dundee Lodge at Dundee Beach. Therefore, the Food Act will not apply to the Project.





Section 10.4, Freshwater Supply


It is noted that during the construction phase that potable water will be trucked to site by a licenced supplier. Suppliers of potable water must be registered with the Environmental Health Branch and potable water should meet the Australian Drinking Water Guidelines.

It is noted that during the operational phase that rainwater and water trucked from off site will be used as the freshwater supply including for potable water. Potable water should meet the Australian Drinking Water Guidelines For further information on maintaining the quality of water from rainwater tanks the proponent should refer to the attached - Guidance on the Use of Rainwater Tank.

Proponent Response

Noted. All potable water used during construction and operational phases of the Project will meet the Australian Drinking Water Guidelines. Potable water trucked to site will be sourced from a supplier registered with the Environmental Health Branch. It is expected that this water will be fit for purpose and will not require further treatment. Rainwater will be treated (20 micron and 1 micron pre-filtration and UV filtration) prior to use to ensure that it will meet the Australian Drinking Water Guidelines.





Section 12.2.5, Waste Management


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It is noted that onsite wastewater disposal systems will be used for the management of sewage. From the information provided, it would appear conventional septic tanks are to be installed. The Department of Health should be notified following the installation of such systems. Should alternative septic tank systems be used approval will be required from the Department of Health prior to installation.

Proponent Response

Noted. As described in Section 2.5.9 of the Project Overview, septic tanks will be installed to manage sewage onsite. The septic tanks will meet the design requirements of the Department of Health's Code of Practice for small onsite sewage and sullage treatment systems and the disposal or reuse of sewage effluent. The Department of Health will also be notified following the installation of the septic tanks.

3.5 DEPARTMENT OF HEALTH - MEDICAL ENTOMOLOGY


Chapter Executive Summary


17 November 2016 Submitters Reference to EIS Section (if provided)

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The Department of Health - Medical Entomology division provided the following comments on the draft EIS:

It is mentioned on the last paragraph of Page 2 ‘Furthermore, in relation to erosion and sediment control, acid sulfate soils, biting insect and weeds, the NT EPA stat (sic) in the SoR that: the NT EPA is satisfied that potential risk associated with erosion and sediment control, acid sulfate soils, biting insects and weeds can be adequately managed through the implementation of standard measures by the proponent. The proponent has committed to preparing and implementing detailed management plans for potential impacts of the project’.

The draft Environmental Management Plan contains strategies for erosion and sediment control, acid sulfate soils and weeds, but not for biting insects. It is therefore recommended that a biting insect management plan/strategy also be created, either as a stand-alone document or for inclusion in the EMP. Previous comments regarding biting insects at Point Ceylon are provided in Attachment 1. If required, Medical Entomology can assist in the preparation of a biting insect plan/strategy.

Attached to the submission were the comments that the Department of Health - Medical Entomology had provided to the NT EPA on the Notice of Intent for the CBC and BMC. These comments were in regards to:

Previous baseline biting insect trapping which had been undertaken by Department of Health - Medical Entomology at Point Ceylon. The Department of Health - Medical Entomology therefore required no baseline biting insect trapping for the Project, however recommended that the information gathered from the previous assessment be incorporated into a biting insect management plan.

The potential for aquaculture developments such as the Project to create new mosquito breeding sites which could affect both workers and residents near the site. The Department of Health - Medical Entomology recommended that the Guidelines for preventing mosquito breeding sites associated aquaculture developments in the Northern Territory be referred to during the development of the Project.


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Proponent Response

A biting insect management strategy has been developed and is detailed in Table 4 below. This strategy has be included as part of the Environmental Management Plan for the CBC and BMC. See Appendix C16 of the draft EMP (Appendix B of this SEIS).

TABLE 4 BITING INSECT MANAGEMENT STRATEGY

Element Detail

Applicable site activities

Site establishment

Operations

Site rehabilitation

Aim

Ensure that mosquito breeding sites are not created or exacerbated through the development of the Project.

Objectives Targets Key Performance Criteria

No biting insect impacts to staff or adjacent landowners

No biting insect nuisance problems

Nuisance levels onsite attributed to biting insects

No occurrences of biting insect transmitted diseases

Number of biting insect transmitted diseases

Responsibility Construction: Construction Manager

Operations: Site Manager

Actions / Mitigation Measures

Standing water (such as in ponds and tanks) will be aerated, and completely drained when not in use. The settlement ponds will not be aerated, but the water within them is constantly moving, so does not provide optimal habitat for biting insects. Rainwater tanks will be appropriately screened at the inlet and outlet.

Culverts and drains will be installed where required along internal farm roads to prevent the shallow impoundment of water.

Inspection of equipment such as tanks, drums, buckets, machinery items and other receptacles sourced from North Queensland for water ponding or evidence of previous water ponding (water stains) to prevent the potential introduction of the dengue mosquito, Aedes aegypti, from North Queensland as larvae or desiccation resistant eggs.

Personnel to wear light coloured, long sleeved shirts and mosquito repellent.

Low intensity yellow lighting will be installed in outside areas, where possible, to minimise attracting insects.

Artificial receptacles will be stored undercover away from rain where possible, or stored in a manner that prevents the ponding of water and creation of mosquito breeding habitat.


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Element Detail

The Project will comply with the Guidelines for Preventing Mosquito Breeding Associated with Construction Practice near Tidal Areas in the NT (Department of Health 2011) and the Guidelines for Preventing Mosquito Breeding Sites Associated with Aquaculture Developments in the NT (Department of Health and Families 2006).

Monitoring Regular surveys for potential mosquito breeding sites within 5 days of rain occurring twice in the wet season and as required during the dry season.

Reporting Occurrences of biting insect transmitted diseases are to be reported to the Construction Manager and/or Site Manager and the Department of Health - Centre for Disease Control

Corrective Actions Consultation with relevant authorities (i.e. Department of Health - Medical Entomology and Department of Health - Centre for Disease Control)

References

Guidelines for Preventing Mosquito Breeding Associated with Construction Practice near Tidal Areas in the NT (Department of Health 2011)

Guidelines for Preventing Mosquito Breeding Sites Associated with Aquaculture Developments in the NT (Department of Health and Families 2006)

3.6 DEPARTMENT OF INFRASTRUCTURE, PLANNING AND LOGISTICS





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Various risks associated with traffic and socio-economic capacity has not been addressed within the EIS, thus the information provided does not allow for adequate comment from this Department.

The document doesn’t include a Traffic Impact Assessment (TIA). A TIA is mandatory to assure the road authority can measure the proponent’s acknowledgement of the risks associated with the works impact on NTG Roads, infrastructure and road safety. A TIA will be required in accordance with AUSTROADS Guide to Traffic Management Part 12: Traffic Impacts of Development. The TIA is to include details on access, vehicle types, volumes of existing vehicles and increased traffic and other relevant matters, including a risk assessment as part of the EIS process to reflect how all roads and infrastructure will be affected. This includes impacts on commercial enterprises and tourist attractions and infrastructure.

Proponent Response

The comments from the Department are noted. However, the issues raised are not in the Terms of Reference for the project, and are therefore outside the scope of the draft EIS. The Terms of Reference for the Project focussed on a number of specific issues around the discharge of water into the receiving environment, waste


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management requirements for solid and liquid wastes, freshwater supply and public interest in the Project. With reference to traffic the ToR required:

The EIS should describe the traffic management requirements, including:

operating times and scheduling

vehicle types, numbers and frequency

the estimated volumes and proposed routes of traffic generated by the proposal

traffic flow management, including site access and signage

This was provided in Section 2.7 of the draft EIS. As such a Traffic Impact Assessment was not required for the EIS. A traffic management strategy however has been developed for the Project and has been included in the draft Environmental Management Plan for the Project (Appendix 19, Table C13.1).

Notwithstanding the above, the proponent commits to preparing an integrated traffic impact assessment and traffic management plan to cover both the CBC/BMC and the Hatchery, and the movements between these two facilities. This will be prepared once the location of the Hatchery facilities has been determined.





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Reference to traffic in the EIS is limited to local Dundee activity, and the risk assessment is limited to local Dundee region as well.

The impacts and risks to the greater Darwin Region, including Berry Springs/Darwin River areas that interact with the Cox Peninsula and other local roads, need to be considered and should be reflected in the risk assessment.

Proponent Response

The issues raised are outside the Terms of Reference and are therefore outside the scope of the draft EIS (see Section 2.6.1 above). A traffic management strategy has, however, been developed for the Project and has been included in the draft Environmental Management Plan for the Project (Appendix 19, Table C13.1).

In addition, the proponent commits to preparing an integrated traffic impact assessment and traffic management plan to cover both the CBC/BMC and the Hatchery, and the movements between these two facilities. This will be prepared once the location of the Hatchery facilities has been determined.





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Risks to increased tourist and local traffic in the dry season for recreational activities are not identified, nor adequately addressed.

Proponent Response

The issues raised are outside the Terms of Reference and are therefore outside the scope of the draft EIS (see Section 2.6.1 above). A traffic management strategy has, however, been developed for the Project and has been included in the draft Environmental Management Plan for the Project (Appendix 19, Table C13.1). This includes measures to manage and mitigate risks to other road users and infrastructure from increased traffic from the Project.

In addition, the proponent commits to preparing an integrated traffic impact assessment and traffic management plan to cover both the CBC/BMC and the Hatchery, and the movements between these two facilities. This will be prepared once the location of the Hatchery facilities has been determined.





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The proponent makes a statement that “traffic concerns are considered low risk to users and infrastructure”, but have failed to provide evidence to support this assumption.

Proponent Response

As discussed in response to Comment 1 (Section 2.6.1) from the Department of Infrastructure, Planning and Logistics, the NT EPA considered that a number of risks were not considered significant and could be dealt with in the Proponent's management plans. A traffic management strategy has been developed for the Project and has been included in the draft Environmental Management Plan for the Project (Appendix 19, Table C13.1). The implementation of the management measures detailed in the traffic management strategy are considered to effectively mitigate the risks posed to road users and infrastructure as a result of the increased traffic movements from the Project.





-


An error in Table 2.7 in relation to truck numbers was noted (Individual trucks don’t add up to total). The numbers and figures throughout the document should be checked for accuracy.

Proponent Response

There was an error in the total number of fuel trucks per month in Table 2.7, which in turn, affected the total number of trucks. This has been rectified in Table 5 below.


37

TABLE 5 OPERATIONAL PHASE TRAFFIC SUMMARY

Truck/m Light Vehicle/m Bus/m Total/m Staff 0 420 28 448 Deliveries Feed 1 0 0 1

General 0 56 0 56

Water* 7 0 0 7 Fuel 8 0 0 8

Other 4 0 0 4 Prawns Founder stock 0 1 0 1

Broodstock 7 0 0 7

TOTAL 27 477 28 532





-


The risks associated with the proposed upgrade of the existing 20m proposed road corridor to 40m (E.g. secure land tenure from Freehold) need to be considered, as well as identify risks associated with the subsequent interface with Fogg Bay Road. This information should be captured within a TIA.

Inconsistent information. TEIS refers to the existing 20m proposed road corridor in the project overview but refer to it as a 40m corridor further on in the document (Section 2.5.5 Road network).

The existing 20m may not be adequate for the purpose of a utility corridor. The risks identified with secure tenure and suitability for utilities needs to be addressed.

Proponent Response

See response to Comment 1 from the Department Infrastructure, Planning and Logistics (Section 3.6.1).

Risks have been previously identified, and as a result the proponent and the government, including the Department of Infrastructure, Planning and Logistics and the Department of the Chief Minister, are involved in discussions regarding many issues associates with road access. Included within the scope of discussions:

required road standard

timing of any road upgrade and timing of identified upgrades identified as necessary and relationship between timing and expected traffic associated with the stages of the proposed development

tenure - including adequacy of existing road reserve and neighbour relations

alignment (including alternatives)

ownership

maintenance.


38

The proponent also notes that given the above it is neither possible nor desirable to address such matters by way of a proponent-based (and therefore unilateral) process as is required in an EIS.

It is anticipated that the agreements arising from these discussions will be captured in a Project Development Agreement which is the normal and usual process within the Northern Territory for a project with Major Project status.

3.7 DEPARTMENT OF PRIMARY INDUSTRY AND RESOURCES





-


The draft EIS, as presented, comprises a comprehensive set of documents that adequately identifies and addresses the risks posed by this component of the Project Sea Dragon prawn farming developments.

The Department of Primary Industry and Resources acknowledges the substantial economic benefit that Project Sea Dragon represents, not only to the Northern Territory, but to the Australian economy.

The scale of this aquaculture project is without parallel in Australia and its successful delivery will have long-standing and far-reaching value for Territory, and especially for regional communities.

Proponent Response

Noted. No response required.

3.8 DEPARTMENT OF TOURISM AND CULTURE - HERITAGE BRANCH


Chapter -



-


The Heritage Branch is satisfied that cultural heritage issues and potential risks have been adequately assessed and suitable control measures incorporated into the Draft Environmental Management Plan.

Proponent Response



39


Chapter Environmental Management Plan



Cultural Heritage Strategy, Table C15.1 and Contingency Response, Table E1.2


However, there are a couple of concerns / suggested amendments to the Cultural Heritage Strategy (Table C15.1) and Contingency Response (Table E1.2) in the Draft EMP:

Cultural Heritage Strategy

Re. monitoring, reporting and corrective actions in the event of an incident or complaint regarding cultural heritage – the proponent should be advised that if any previously unidentified archaeological / cultural heritage sites or objects are encountered, or there is an incident involving cultural heritage sites or objects, the Heritage Branch, Department of Tourism and Culture, should be notified immediately and any advice provided by the Heritage Branch should form part of the corrective action employed.

Contingency Response

As above, if any previously unidentified archaeological / cultural heritage sites or objects are encountered, or there is an incident involving cultural heritage sites or objects, the Heritage Branch, Department of Tourism and Culture, should be notified immediately and any advice provided by the Heritage Branch should form part of the corrective action employed.

Proponent Response

The Cultural Heritage Strategy in Table C15.1 has been updated to include the following text (see Appendix B):

The Heritage Branch will be notified in the event that previously unidentified archaeological / cultural heritage sites or objects are encountered, or there is an incident involving cultural heritage sites or objects. Any advice provided by the Heritage Branch will form part of the corrective action.

The Contingency Response for Unexpected Findings in Table E1.2 of the draft Environmental Management Plan has also been updated with the following text:

Advice will be obtained from the Heritage Branch, Department of Tourism and Culture, and the Aboriginal Party for the area to determine the nature of the find (in conjunction with an archaeologist/anthropologist as required). If a genuine cultural heritage find, the cultural heritage register will be updated with the find

Any corrective actions will include the advice provided by the above parties.


40

3.9 DEPARTMENT OF TOURISM AND CULTURE - PARKS AND WILDLIFE


Chapter -



-


Adjacent to Indian Island – no longer parks estate sitting with Land Trust.

The Department of Tourism and Culture - Parks and Wildlife had no further comments.

Proponent Response


3.10 DEPARTMENT OF TOURISM AND CULTURE - TOURISM NT





-


Bynoe Harbour is a significant tourism area with a number of well-established operators. Tourism NT understands that the proponent has conducted some consultation to date, including with residents; however it is not clear whether direct consultation has occurred with tourism businesses in the area (beyond The Lodge of Dundee) such as Crab Claw Island Resort and the Sandpalms Roadhouse and Tropical Motel. Tourism NT suggests such contact occur and is happy to facilitate a meeting or distribution of information to relevant tourism operators.

Proponent Response

As detailed in Socio-economic chapter of the EIS (Chapter 14) and the Dundee Consultation Report (Appendix 12), consultation was undertaken with the local community regarding the Project. Information brochures regarding the Project were distributed to the general public and local businesses. Additionally the general public and local businesses were invited to attend a number of information sessions about the Project. No comments were received from either the Sandpalms Roadhouse or the Tropical Motel following consultation. The proponent considers that sufficient consultation has been undertaken with local businesses and tourism operators.


Chapter Other



-


41


The EIS and supporting documentation adequately addresses other matters of interest to Tourism NT.

Proponent Response


3.11 DEPARTMENT OF TRADE, BUSINESS AND INNOVATION





-


The Department of Trade, Business and Innovation (DTBI) does not have any major issues with the project's draft EIS.

The Core Breeding and Broodstock Maturation Centres are integrated components of the larger Project Sea Dragon land-based prawn aquaculture project. An assessment of the economic benefits of the CBC and BMC in isolation would be difficult. The EIS presents a hypothetical scenario which defines the benefit of these facilities over the use of wild caught prawns to stock the hatchery. These facilities provide significant productivity growth through selective breeding. The potential economic benefits of the wider project are outlined in the EIS for Project Sea Dragon - Stage 1 Legune Grow-out Facility that was released earlier.

The EIS provides valuable information on employment and business opportunities in the construction and the operational phases of the Centres accruing to the Territory including the local region in which the Centres are located.

Proponent Response


3.12 ENVIRONMENT CENTRE

3.12.1 Comment 1 Submitter Type Community Environment

Group (independent) TOR Category or EIS Chapter

Project Description



-


To ensure best environmental and sustainable aquaculture practices, this proposal must comply with Shrimp Standards as prescribed by the Aquaculture Stewardship Council (ASC). The Operator must also obtain certification and accreditation by the ASC in accordance with their guidelines. Approval of this proposal should be conditional on the Operator obtaining and maintaining these standards.


42

Proponent Response

The proponent has undertaken an internal audit finding the Project can comply with the requirements of the Aquaculture Stewardship Council (ASC) Shrimp Standard. However, ASC accreditation is based on a third party audit process and as such Seafarms is unable to unilaterally declare that it is able to obtain such accreditation. The proponent does commit to undergoing the audit and processes to achieve accreditation; however, it is noted that the ASC Shrimp Standard is a global standard and there are parts of the ASC standard that may conflict with Australian laws - laws which will in all cases be complied with in the event of any conflict with the ASC standard requirements. More importantly, accreditation cannot be obtained before operations commence because the operations themselves are audited as part of obtaining certification. Thus, it is technically not possible to approve the proposal 'conditional upon'.


Group (independent) TOR Category or EIS Chapter

Project Description



-


To ensure transparency and monitor impacts on the environment, a condition of this proposal must be that the Operator of the facility agree to fund a robust and independent monitoring program of the entire operation and its activities at an agreed frequency and at an agreed level of detail.

a. The level of funding required for the independent monitoring program must be sufficient to undertakeongoing monitoring for the life of the project. The funding must be deposited into an independent accountprior to any works commencing.

b. The frequency of monitoring and the level of detail of the monitoring must be defined through a publicprocess funded by the Operator.

c. The independent monitoring program should be comprised of recognised experts in their field.

d. The monitoring program will include triggers where the operation will be required to cease work if theagreed levels are exceeded and financial penalties will be imposed if this requirement is not met. Themonitoring program should work with the appropriate NT government agencies to ensure compliance.

Proponent Response

The proponent notes the comments. Chapter 4 of the draft EIS outlines the legislation and the approvals required for construction and operation of the facility. The EMP for the Project sets out specific targets for monitoring programs, which will be predominately determined through 'secondary' approvals (where they are properly addressed [e,g. waste discharge licences, vegetation clearing permits]). The undertaking of monitoring programs are considered part of operating costs of the facility and are thus funded from cash-flow. The updated draft EMP can be found at Appendix B of this SEIS.


Organisation TOR Category or EIS Chapter

Other



-


43


To safeguard against serious environmental damage, a requirement of this proposal should be that the Operator post a bond with the NT government for this facility that will be sufficient to cover any operational failures. This bond should also be sufficient to properly remediate the site to an agreed standard when the operation ceases. This bond should be deposited into an independent account prior to any works commencing.

Proponent Response

The draft EIS, through the comprehensive risk assessment (Chapter 6) shows that overall the risk of serious environmental damage is low. The draft EMP (see Appendix B) shows how specific risks shall be mitigated and managed. Section 2.10 of Chapter 2 of the draft EIS outlines contingencies for decommissioning and rehabilitation.



Flora and Fauna



-


To protect the local biodiversity at the site in question, this proposal must require the Operator to ensure surrounding ecosystems and connectivity between habitats is maintained. This includes restoring any habitat lost as a result of this project such as mangrove forests.

Proponent Response

As described in Section 9.4.1 of the draft EIS, the total anticipated clearing required for the Project is 150 ha which constitutes less than 0.5% of the vegetation within the entire Lower Finniss Region. The majority of the vegetation within the Project clearing area is mapped as open woodland of Eucalyptus tetrodonta, Eucalyptus miniata and Erythrophleum chlorostachys. This community (Vegetation Community Code A1) is widespread across the region and the area surrounding the Project site. Furthermore, the clearing will not result in the isolation of any tracts of habitat (see Figure 9-1 of the draft EIS) or significantly reduce connectivity across the site. As such the clearing of vegetation is not anticipated to constitute a significant impact and will not result in a loss of biodiversity values or connectivity between habitats.

Additionally, the Project has been designed to minimise the clearing of mangroves. The construction of the discharge release point will only require the clearing of 0.66 ha of mangroves. The NT EPA concluded in the Statement of Reasons, that "it is unlikely that impacts to mangroves would be significant relative to the extensive mangrove forest that exists along Wheatley Creek and more widely in the region".



Other



-


44


To prevent large scale trawling and depletion of wild fish stock, this proposal must minimise the use of wild fish as an ingredient for prawn feed and declare all sources of fishmeal, fish oil and other major ingredients in the feed.

Proponent Response

The proponent intends to pursue accreditation from the ASC. The ASC standards provide guidance on ethically sourcing feed.

Feed for the CBC and BMC will be sourced from third party manufacturers. Australia currently has two suppliers of feed that service the domestic market, and the proponent also sources feed internationally. All imported feed is subject to strict Australian Quarantine Inspection Service requirements and prawn feed is regulated through the Department of Agriculture. The proponent has examined near-to-market feed innovations including CSIRO's patented Novacq technology but has not been able to trial the product. Feed manufacturers continually improve and modify primary feedstocks and the exact ingredients are usually considered commercial-in-confidence or trade secrets. The proponent has adopted an 'Ethical Sourcing Policy' for its feed to ensure it is sourcing its products in a responsible manner, it is providing clear guidance to its buying staff, and is protecting its corporate reputation and the reputation of its individual brands.

The proponent also notes that development of feed is the subject of a global research and development effort with the aim of reducing inputs from wild-caught fisheries and thus feeds are constantly changing.



Other



-


In order to prevent contamination and degradation of both water and soil quality, this proposal must ensure that there is licencing and applicable fees applied for the proper and safe disposal of waste materials, including waste water.

Proponent Response

Chapter 4 of the draft EIS outlines the regulatory framework applicable to the Project. As stated in this chapter, the purpose of the Waste Management and Pollution Control Act (NT) is to protect the environment through the encouragement of effective waste management and pollution prevention and control practices. The proponent will apply with the appropriate approvals and licences under the Act for relevant activities during the construction and operational stages of the Project. For the discharge of water to Wheatley Creek, a waste discharge licence will be obtained under the Water Act (NT).



Waste Management



-


45


To ameliorate environmental impacts, consideration must be given to the possibility of licencing for extraction of sea-water for commercial purposes.

Proponent Response

As discussed in the response to Comment 11 of the NT EPA's submission (Section 3.14.11), the proponent will obtain a licence under the NT Water Act to extract seawater from Bynoe Harbour.



Flora and Fauna



-


To protect threatened, endangered and protected species, a standard should be set that requires no intentional killing or harassment of protected, threatened or endangered animals that prey on cultured shrimp.

Proponent Response

All terrestrial and avian predators will be excluded from CBC and BMC facilities. Tanks and raceways will be covered to prevent predation by birds (see Figures 2-3 and 2-4 of the draft EIS) and a chain mesh fence will installed around the boundary of both the CBC and BMC facilities to prevent the ingress of any terrestrial predators. As such, no culling of predators or scare tactics (e.g. use of sirens, gunshots, lights, drones, helicopters, water sprinklers, dogs) are necessary, so will not be employed at the facilities.



Waste Management



-


The proponent should be required to recycle all waste water and keep all waste water and recycled water on the prawn farm site. No waste or recycled water should be allowed to be released off site.

Proponent Response

In accordance with the Australian Prawn Farmers Code of Practice, the design has been undertaken with a view to minimising raw water intake, maximising internal recycling, and eliminating inappropriate disposal of other wastewaters, such as oils and chemicals, and wastewater on the site.

However, to operate a prawn aquaculture project, a certain amount of water exchange is required, primarily driven by the salt balance. While recycling and hence nutrient re-use is maximised, at a fundamental physical mass-balance level it is ultimately constrained by salinity.

Regardless of the above, the discharge has been shown to meet suitable quality to avoid impacts to the receiving environment, meeting water quality triggers outside of the initial mixing zone (see the draft EIS, Section 11.5, particularly 11.5.8). As such, a completely no-release operation, apart from being impossible, is


46

entirely unnecessary. Note also that the discharge will continue to be managed under a waste discharge licence obtained under the Water Act (NT).

In terms of other wastewaters, all sewage will be treated on-site, and treated effluent disposed through land application areas, designed to ensure long term sustainable operation, and to appropriate NT government standards, particularly the Department of Health's Code of Practice for small onsite sewage and sullage treatment systems and the disposal or reuse of sewage effluent.

Other wastewaters (oil, chemicals, etc.) will be removed off-site by licenced contractors to licenced premises, and treated, recycled or disposed according to NT legislative requirements.

3.13 IAN AND PAT STEWART

3.13.1 Comment 1 Submitter Type Public TOR Category or EIS

Chapter Other



-


Please note that we do not accept the proposition implicit in the document that the Paspaley pearl operation is more important than the health, lifestyle and amenity of Dundee Downs residents.

Proponent Response

The proponent disagrees with statement that the draft EIS implied that the Paspaley pearl operation were more important than the health, lifestyle and amenity of Dundee Downs residents. The purpose of the EIS process is to identify, assess and mitigate the impacts of the Project on both the environment and community. The Paspaley oyster leases were identified as a potentially sensitive environmental receptor given their proximity to the Project site. Therefore, measures were put in place to avoid and/or mitigate any potential impacts to the leases. This included designing the intake to avoid the leases and siting the release point away from them.

Similarly, the same process has applied to potential impacts on the local Dundee community. Potential impacts from the Project which may affect Dundee residents (e.g. air emissions, noise, increased traffic, limitations on recreational fishing access) have been assessed in the EIS and, where applicable, management measures have been put in place.

Additionally, the EIS process for the Project also involved consultation with parties who may be potentially affected by the development in order to address any concerns. This has included consultation with both the local Dundee community and Paspaley. Full details of the consultation undertaken for the EIS are provided the Chapter 14 of the EIS.





-



47

We understand that the proposal for a tidal weir across Wheatley Creek has been withdrawn. We still suggest that there be a requirement to guarantee that there will be no impediment to navigation in Wheatley Creek.

Proponent Response

The tidal weir that was proposed as part of the Notice of Intent for the Project was proposed to be constructed along the bank of Wheatley Creek. It was never intended to be built across Wheatley Creek where it could impede navigation.

It is now proposed that instead of the tidal weir at the discharge point, water will held in release control ponds until it can be released on the mid to high tide. It will then be released along the discharge release channel to the release point situated on the bank of Wheatley Creek. The discharge release channel and release point will consist of riprap channel and will not pose any impediment to the navigation of Wheatley Creek.





-


All water quality data collected to date and in the future from the nominated testing sites must be readily available to the public.

Proponent Response

The proponent will apply for a waste discharge licence under the Water Act. The NT EPA is the administering authority for waste discharge licences and will monitor compliance with the conditions of the waste discharge licence. The proponent will be required to submit Annual Review and Compliance Report, and provide monitoring reports, including a trend analysis and interpretation of all monitoring data to the NT EPA.

In the spirit of transparency, the NT EPA makes the waste discharge licences as well as any environmental plans and annual audit and compliance reports required as a condition of waste discharge licence available to the public on their website at http://www.ntepa.nt.gov.au/waste-pollution/approvals-licences/wd-licences.





-


Effluent outfall into Wheatley Creek to be via pipeline exiting below water level; or if not practicable, via such means that there is no erosion of the creek banks or damage to mangroves. Visual aesthetics must be taken into consideration.

Proponent Response

A pipeline to convey waste water to the discharge point was considered as a potential option. It was not, however, feasible as it would be difficult to maintain due to marine fouling. This would have resulted in the requirement for regular chlorination and higher downtime for mechanical cleaning.


48

A better operational and environmental outcome is achieved through the discharge release channel as it allows for the diffuse release of the discharge water rather than point source release of a pipe. This aids in the rapid dispersion and dilution of the waste water in the environment. Additionally an open channel can assist with aeration and exposure of the discharge water to the atmosphere can also facilitate denitrification through volatilisation.

The discharge release channel has been positioned in an area which minimises the clearing impacts to mangroves and will be lined with riprap to prevent erosion. Additionally it will only be able to be seen from parts of Wheatley Creek that are within the immediate vicinity. The mangroves which are present along the banks Wheatley Creek will also assist in screening the discharge release point. Therefore the impact on the visual amenity of the area will be low.


Chapter Other



-


Signage is posted at the outfall site visible to waterway users advising of its existence and that water quality may be below that of surrounding waters for a specified distance in each direction.

A visible signal [eg VMS-style sign] operates in conjunction with the signage mentioned above whenever actual discharge is occurring.

Proponent Response

There is no requirement for the proponent to erect any signage at the discharge point. Water discharged from the CBC and BMC will contain nutrients, namely nitrogen and phosphorus, and primary producers (e.g. algae) indicated by chlorophyll a, all of which naturally occur in the local environment. There will be no release of any toxicants that could potentially impact on the health of waterway users. As such, the proponent does not consider that there is any merit of installing signage at the discharge point and potentially in doing so may unnecessarily alarm people.

No marine hazard of any kind is envisaged, although should there be any hazards due to any part of the project, appropriate mitigation and signage would be implemented.





-


The document makes no mention of measures to protect the chain of billabongs which the access road crosses at approx. 3.2km during road upgrade.


49

Proponent Response

No billabongs have been identified on or adjacent to proposed access road or on the larger Project site. This is despite numerous surveys and site inspections undertaken for both the Point Ceylon (Suntay) Aquaculture Estate development and this Project.





-


It is disappointing that a greenfield development such as this which espouses best practise in environmental matters does not incorporate ANY renewable energy component but relies solely on diesel generation for its 6MW of electricity.

Proponent Response

This comment has been addressed in the response to Comment 1 from the Department of the Chief Minister (Section 3.2.1).

3.14 NORTHERN TERRITORY ENVIRONMENT PROTECTION AUTHORITY

3.14.1 Comment 1 Submitter Type Northern Territory

Government TOR Category or EIS Chapter

Project Description



Figure 2-2


Stage 1 appears to be one quarter the size of future stages with half the number of discharge water and release control ponds. Clarify whether the number of discharge water and release control ponds will be sufficient to treat waste water for future stages of the CBC.

Proponent Response

The total requirement for discharge and release control ponds at full development has been determined to be sufficient for the fully developed Project site. However in developing the site, it is more economical to build these structures in a smaller number of stages, each essentially being larger than required for the immediate stage.

The Stage 1 ponds are anticipated to be sufficient to handle flows from Stages 1 - 2, with future upgrades occurring as needed, at this point anticipated before Stage 3 commences.

The adequacy of the design is clarified further in our response to NT EPA's comment 5 (see Section 3.14.5)


50



Project Description



Section 2.5.3.1


In the Notice of Intent (NOI), the proponent stated that piling for anchoring of the seawater intake pipe would be unlikely to be employed and the statement of reasons indicates that piling was ruled out by the proponent based on further information supplied by the proponent. The draft EIS indicates that piling may be required. Clarify whether or not pile driving is likely to be required and whether screw anchoring is synonymous with piling.

Proponent Response

Design of the Project has progressed such that the proponent is now able to rule out the potential for pile driving. No pile driving will be undertaken as part of the Project. The seawater intake pipeline will be secured by screw anchors or gravity anchors placed on the seabed. Screw anchoring is not synonymous with pile driving as there is a low noise level, and minimal vibration, associated with installation (screw piles are driven into the ground much as a screw is driven into wood).



Project Description



Section 2.5.3.2


Discharge of 5% of intake water along with residual particles from filters

Coarse particles (suspended sediment) filtered from the seawater following the intake will be discharged sub- tidally into the harbour. This discharge was not mentioned in the Notice of Intent. The draft EIS estimates 5% of seawater intake will be discharged in this way, which equates to approximately 11L/s (if full scale development has capacity to pump 222 L/s).

Identify the location of this discharge and its proximity to sensitive receptors, discuss its potential effects on the receiving environment e.g. turbidity and sedimentation, and advise an appropriate monitoring regime.

Proponent Response

Intake seawaters will be filtered prior to waters entering the facility to remove any coarse suspended solids. Any captured material in these filters will be returned to the local coastal environment in a seawater solution. Discharge will occur at the filtration discharge outlet, located on the same alignment as the intake pipeline, north of Ceylon Point in Bynoe Harbour. By following the same alignment as the intake pipeline, construction of the filtration discharge pipeline will result in no additional construction impact. While the proposed intake point is located approximately 2 km from the coast to allow continued access to open seawater in all tidal conditions, the discharge pipeline will be substantially shorter, with the outlet located approximately 750 m north of the intake pump station, immediately below the mean low tide mark. Impacts and sensitive environmental receptors associated with construction of the intake pipeline were discussed in Section 3.2 of Appendix 13 of the EIS. As no additional construction is required, there will be no additional construction-


51

related impact related to filtered material discharge. Impacts associated with operational discharge of the filtered material are, however, provided following.

The process of filtration will involve a coarse screen mesh located at the seaward end of the intake pipe to prevent debris and marine fauna from entering the intake pipeline. This will be followed at the land intake point by a series of mesh filters that will ultimately screen out sediments larger than 400 µm and allow unimpeded flow of seawater and finer sediment. This filtered seawater (and any fine suspended sediments) will pass into the facility and will be managed in settlement ponds. To prevent any internal build-up or accretion of sediment within the intake pipeline, the pumping process will incorporate a periodic backwash of the intake line. This will apply reversed pressurised flow of water pumped from the seawater intake pump station. The backwash will be activated by a pre-determined time trigger. This will flush the system under a minimum of 30 psi for a period of 20 seconds. The backwash system will utilise untreated seawater already present within the intake line and pump station facility and discharge will be directed via the discharge line to be released at the filtration discharge outlet. As detailed in Section 2.5.3.2 of the EIS, this process is expected to see a maximum of 5% of intake waters discharged back to coastal waters at the outlet. With full scale development, maximum flow of 11L/s (5% of 222 L/s) will be discharged during any backwash event. Noter also that these backwash events will only occur when the pump is operational (i.e. mid to high tide). Water used to backwash the intake line will not enter the processing facility. Discharged seawater will not be treated in any way and will therefore be comparable in chemical and nutrient composition to the seawater received from the intake point, minus any of the finer sediments that will pass through the coarse filters. The level of suspended sediment released from the filtration discharge outlet will therefore vary seasonally, as a direct result of seasonal variation in turbidity levels within Bynoe Harbour and the resulting intake waters.

As detailed in Appendix 13 of the EIS, the receiving environment in the vicinity of the filtration discharge outlet is a shallow marine environment with relatively coarse sand/gravel substrates and loose boulders. A large intertidal rocky reef extends 450 m north of this location. In deeper waters sponges and soft corals dominate reef benthos of Bynoe Harbour, together with hard corals of the genus Turbinaria (Smit et al., 2000). However, the nearshore rocky reef is tidally exposed and these sensitive reefal taxa are not known to be prevalent in this area. Taxa such as oysters, chitons and limpets are common inhabitants of intertidal rocky reefs.

As detailed in Appendix 17 of the EIS, the combination of a large tidal range within Bynoe Harbour (7.6 m) and shallow waters off Ceylon Point, mean the area is subject to coastal currents ranging between 0.2 - 0.25 m/s during neap tides and 0.7 - 0.75 m/s during spring tides. As a result, local sediments are typically coarse, with finer sediments settling in areas of lower flow along Geranium Channel to the south-west and in the area of mangroves immediately east of Ceylon Point, west of Toss Point. Like the rest of Bynoe Harbour, water quality at the discharge outlet is characterised by significant seasonal variation in turbidity with ranges in nearby waters previously measured to flux between 1.7 and 10 Nephelometric Turbidity Units (NTU). Increased run-off from the catchment during times of high rainfall causes a significant increase in turbidity during the wet season. Water visibility drops to 0.3 m during that time of year, compared with 8 m visibility in the dry season (Enesar, 2006). The seasonal increase in turbidity will require more frequent discharge of water from the filtration discharge outlet to filter out the higher load of suspended solids within intake waters during the wet season.

The release of seawater containing coarse suspended sediments from the filtration discharge outlet is expected to have negligible impact on the local receiving environment. Seawater released will be directly comparable to that present within Bynoe Harbour. During the dry season when water clarity is high there is potential for a very small localised sediment plume at the sea bed below the lowest astronomical tide, adjacent to the filtration discharge outlet. This will be composed of coarse marine sediments (> 400 µm) that are already


52

suspended within the water column at the intake point. This is expected to be assimilated into the background water quality rapidly with limited detectability beyond the immediate discharge point.

Increases in sedimentation and turbidity that adversely impact marine fauna, through the disruption of filter-feeding and displacement of light dependent species, are generally associated with increases in fine sediment (Davies-Colley and Smith, 2002). Fine sediments have a greater tendency to clog the gills of filter-feeders and more readily block light than coarse sediments (Lin et al. 1992; Toveret al.2000; Davies-Colley and Smith, 2002). Given the turbidity of seawater within Bynoe Harbour naturally ranges between 1.7 and 10 NTU, a relatively small, localised injection of coarse sediments at the filtration discharge outlet is not considered to be sufficient to elevate turbidity levels above the 20 NTU trigger point identified in the Australian and New Zealand Guidelines for Fresh and Marine Water Quality (ANZECC, 2000) for slightly to moderately disturbed estuarine and marine waters (Environment Australia 1998). The suspended sediment that will be discharged will have been extracted from intake waters and, therefore will occur in natural suspension within the local environment such that the proposed action is not considered to contribute to sediment loading beyond that which naturally occurs. Wet season peak inundation is expected to cause greater variance in turbidity at the site than any filtration discharge. The increase in turbidity from the filtration discharge is therefore considered unlikely to adversely impact local marine fauna or flora. Given the local benthic environment is already subject to moderate to high levels of seasonal variation in turbidity, it is considered to show resilience to the levels of turbidity that will occur at the filtration discharge outlet.

Discharged filtered materials will be > 400 µm in grain size; and represent suspended solids already present in intake water that will be returned to coastal waters. Any one backwash event will last a maximum of only 20 seconds. At the point of discharge, cross currents and tidal exchanges create strong local currents (as detailed in Appendix 17 of the EIS). These are expected to entrain coarse sediments returned back into local waters. Therefore, no build-up of sediments at the filtration discharge outlet is expected and any end of pipe discharge plumes are expected to be readily assimilated into the surrounding waters.

The pipeline will be buried to -5 m AHD to avoid impact to coastal processes. Given the benign nature of the seawater and sediments to be released, the apparent stability of the geomorphology at the site of discharge (see Appendix 17 of the draft EIS) and the seasonally dynamic nature of local waters, the discharge is considered unlikely to impact on local marine flora, fauna or ecosystem processes. Given that environmental impacts are considered highly unlikely, no dedicated monitoring is considered required at the filtration discharge outlet, other than visual monitoring that will be undertaken as part of the broader environmental management program for the facility.

In the event that a sediment plume is visually observed, if this extends > 50 m away from the discharge point and persists for > 1 hr, routine elevated investigation of this would be undertaken to confirm that all discharge works were operating appropriately and investigate cause of plume. This investigation would include examination of causal factors to inform appropriate management intervention to prevent future occurrences. This information would inform the management of the discharge regime (e.g. altering discharges under certain tidal cycles). This provision has been included in the draft EMP (see Appendix B of this SEIS).



Project Description



Section 2.5.4.1


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This comment comprises of two distinct issues which have been dealt with separately in the proponent's response.

Issue 1

A discharge rate of 12 440 kL/day at full scale is 1 400 kL/day greater than was proposed in the NOI. The EIS must provide comment on why modelling of the 11 000 kL/day discharge rate is considered appropriate to predict impacts of a larger discharge and what the potential impacts to water quality are likely to be if the rate of 12 440 kL/day is realised (in terms of the modelling predictions).

Issue 2

Please provide information on the likely permeability factor (K value) for the HDPE to be used in the HDPE-lined drains reporting to the discharge water ponds from the CBC and BMC (shown in Figure 1-4).

Proponent Response

Issue 1

The new discharge rate is 12% larger than that modelled in the work prepared for the NOI. The following explanation for this change was provided in Section 11.5.3 of the EIS:

“Detailed design is currently occurring in parallel, and to facilitate a buffer on design solutions, volumes are being considered up to 12,500 m³/day. However, modelling of 11,000 m³/day is considered realistic for site operations at this phase as full scale design solutions may not be realised and are likely, for cost reasons, to be rationalised. Accordingly modelling findings for the 11,000 m³/day scenario are considered relevant to understanding potential discharge risks.”

Higher discharge rates may potentially result in higher concentrations of nutrients within Wheatley Creek due to the increase in discharge volume and total nutrient load (assuming that the concentration of nutrient in the wastewater remains constant and hence increases in load are related to increases in discharge volume).

The modelling has assessed the dilution and dispersion of a conservative model tracer, representative of effluent water from the facility. The modelling considered a constant discharge rate at 11,000 m3/day.

As noted in Figure 3-8 of Appendix 17 of the EIS (shown below in Figure 4), the concentration of discharged material within Wheatley Creek is less than 5% of the inflow during the dry season when freshwater flow did not increase dilution and dispersion of model tracer. The corresponding concentrations of total nitrogen (TN) and total phosphorus (TP) are presented in Figure 3-10 of Appendix 17 (shown below in Figure 5) and indicate levels of nutrients are well below proposed interim trigger levels.


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FIGURE 4 VARIATION OF MODEL CONDITIONS AT POINT 1 UPSTREAM OF THE DISCHARGE POINT OVER A TWO MONTH PERIOD (DRY SEASON CONDITIONS)

FIGURE 5 MODEL CONCENTRATION OF TOTAL NITROGEN (TOP) AND TOTAL PHOSPHORUS (BOTTOM) FOR DRY SEASON CONDITIONS


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Increasing the discharge rate by 12% could result in a 10-15% increase of nutrient concentrations above modelled levels. This would result in minor increases in the predictions of additional nutrient levels in the system associated with the discharge. As shown in Figure 6 in Appendix 16 (reproduced in Figure 6 below), an increase of 15% would result in an increase in the median additional level of TN of 0.009 mg/L and an increase in median additional TP of 0.002 mg/L, in both cases still well below the proposed interim trigger levels.

The impact of an increased volume of water on the tidal prism is also expected to be minor with the increased discharge of 6,220 m3 during a tidal cycle being an addition of 0.12% (compared with 0.11%) and 0.62% (compared with 0.55%) of the creek tidal prism for spring and neap tides respectively. This is unlikely to have any impact on large scale tidal water levels.

FIGURE 6 ADDITIONAL DISCHARGE INTERPRETATIONS

Issue 2

The hydraulic conductivity (otherwise referred to as the K value) of the HDPE to be used to line the channels is 1 x 10-14 m/s. HDPE liners are essentially impermeable and commonly used in wide ranging containment applications including potable water storage, animal waste containment, landfills and canal linings.


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Project Description



Section 2.5.4.2


This comment comprises of three distinct issues which have been dealt with separately in the proponent's response.

Issue 1

The draft EIS states that the suspended sediment in waste water reporting to settlement ponds is high in organic materials such as unutilised feed. Discuss the expected feed use efficiencies and how the incidence of feed in waste water can be reduced to as low as reasonably practicable.

Issue 2

Settlement ponds have been designed to enable 60-hour residence time to maximise the settlement capability ponds.

Provide evidence that 60 hours is sufficient duration of residence time in discharge water ponds to ensure the typical sediment particle sizes are able to settle out of suspension and, similarly, the effect on nutrients.

Issue 3

There is limited capacity for ponds to overflow as the ponds are designed to store an additional 500 mm of rainfall. However, to mitigate for an extreme rainfall event greater than 500 mm, the design allows overflow from one pond to the next via a lined overflow spill way. The final release of overflow water is through a lined spill way that discharges into Bynoe Harbour below the high-tide mark.

Provide details of:

the ARI rainfall event that would exceed the 500 mm freeboard allowance

the management of ponds to ensure that 500 mm freeboard is maintained, particularly after significant rainfall events, without compromising the purpose of the discharge water ponds.

Proponent Response

Issue 1

Feed is expensive and feeding costs represent a considerable portion of the operating budget, so excess feed is a waste, providing a commercial imperative to minimise over-feeding. Animal health and water quality will be constantly monitored, as will feed consumption. Multiple daily feeds allow for regular monitoring and adjustment of feed amounts. If there is excess feed remaining after one of the daily feeds it is normal practice to reduce or skip the next feed to ensure excess is consumed, to achieve both the best feed conversion ratio (FCR - FCR is a measure of the mass of food applied to ponds vs the mass of prawns produced) and optimal growth rates.


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This reduces impacts on water quality within the growing facilities, as pumping water is expensive. Ensuring excess feed is minimised and removed regularly is important in managing and controlling the biomass and subsequent water quality to prevent health impacts/stressing the prawns and subsequent impacts on growth. So there is a water quality objective not to overfeed in both prawn health and minimising pumping costs, regardless of the limits posed by the discharge licence.

Commercial prawn pellets (diets) that will be used have also been developed to maximise digestibility and nutrient uptake, minimising waste through excretion and amount of feed need to be provide to achieve the prawns daily nutrient requirements achieving low FCR’s. They have also been designed for their stability within water, meaning they hold their shape, ensuring the feed does not disintegrate and therefore is available for the prawns to eat.

The systems within the CBC and BMC have been designed from established practices (e.g. Australian Prawn Farming Manual; M Burford, et al 2001; research programs by Griffith University; CSIRO; Qld Dept of Agriculture and Fisheries, etc ) and experience at the Company’s Queensland operations with feeding levels and water exchange being adjusted as part of the routine practice and commercial management, taking into consideration:

Breeding Centre stocking rates for all tanks, raceways and ponds, and whether the raceways and tanks are covered or not (reduced stocking rates compared to commercial prawn production).

Target feed conversion rates (FCR), duration, digestibility and potential waste generation at different stages of the animal growth.

The estimated accumulation and potential sludge rates and volumes.

Going forward, given that feed is a significant cost to production there is a massive incentive to increase efficiency of feed utilisation. As well as the above considerations, there are many other factors that could come into play that would reduce the FCR, and improve yield. For example, feed formulas that improve the FCR, selective breeding for higher performing animals, as well as advances in the feeding regime have all been shown to reduce FCRs, and hence improve yield.

Issue 2

Settlement ponds have been sized based on industry research conducted by CSIRO (Jackson et al. 2003) to account for the peak and average sediment loads, and consistent with the Australian Prawn Farmers Association Guidelines. This research showed that total suspended solids (TSS) was reduced by 60% with a residence time of approximately 17 hours. In addition to the settlement of suspended solids, the residence time allows for reductions of total phosphorus and total nitrogen. The recommended optimum requires approximately 48 hours residence time.

The 60 hours is a conservative figure based on normal average flows and takes into account:

Settling times of the sediment components.

The variation in daily throughput and water exchange rates.

The desired nutrient reduction.

Further size and residency time reduction could be achieved based on introduction of natural filtration system (e.g. oysters), but have not been adopted owing to the added complexity, the remoteness of the site and the need to keep the operability low and reliability high under all seasonal conditions.


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Issue 3

The 500 mm freeboard was selected to cater for a 100 ARI event, assuming no active controls.

The raw and discharge water storage ponds are designed to recognised standards (ANCOLD). The standard is risk-based and considers both passive and active controls. The storages are considered low-risk facilities due to the probable severity of damage and loss to human life, the environmental and associated facility assets.

The ponds will be sited away from large catchment areas with the ground levels contoured to minimise any surface water directed towards the ponds. Any rainfall or surface water that enters the storage ponds will be consumed by the process or safely discharged via overflow from one pond to the next, with final release in a controlled manner through the release point. All ponds are located above the 5 m AHD to reduce any interaction will storm tides and surge.

In practice, the operations personnel would actively manage the settlement ponds and all other water retaining structures to ensure that any overtopping risk is minimised using weather forecasting, instrumentation, alarms and water level controls. It is worth noting, that, in effect, to overflow the 500 mm freeboard, there would need to be a rainfall event that exceeded 500 m in a 24 hour period, which has never yet occurred in the Darwin region. A management protocol will govern controlled releases.



Project Description



Section 2.5.4.3


The draft EIS states that discharge release control ponds may be installed in stage 2 should additional management of water be required to meet water quality objectives. The NOI proposed a tidal weir/pond to regulate the discharge water quality into Wheatley Creek. There is no tidal weir mentioned in the main sections of the draft EIS and Figure 2-7 shows quite a different configuration for discharge than what was proposed in the NOI. Provide reasons for not proposing a tidal weir in the draft EIS and justify the decision not to include release control in stage 1. Provide criteria that will inform the decision to install release ponds and control the release in later stages of the project.

It should be noted that the NT EPA’s Statement of Reasons identifies the tidal weir as a factor in the decision that the discharge is ‘not likely to significantly affect the regional water quality of Bynoe Harbour’. It should also be noted that the water quality objectives in the NOI and draft EIS are considered interim values only until enough data are collected by the Proponent to determine whether or not these are appropriate for operation.

It is unclear from Figure 2-7 how the release point for the discharge channel is configured. Further detail is required on the discharge release point including how the water will be delivered to the receiving environment i.e. actively pumped or gravity fed, continuous flow or intermittent flow, etc. If the discharge point releasesonto salt marsh adjacent to Wheatley Creek as it appears in Figure 2-7, discuss the implications for scouring ofthe salt flat, sediment transport into the creek and eutrophication or modification of mangroves.

Proponent Response

A tidal weir was proposed at the time the NOI was submitted. Following detailed design, however, release control ponds were determined to be a more optimal solution. Similar to the tidal weir, the release control ponds allow for water to be stored until it can be released on the mid to high tide. The release control ponds,


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however, would be built adjacent to the settlement ponds above 5 m AHD. This avoids the construction of a weir and associated tidal mixing pool in the intertidal area, reducing the risk of disturbance of acid sulfate soils and minimising the area of mangroves required to be cleared.

The discharge point will not release directly on to salt march. It is acknowledged that Figure 2-7 is ambiguous in relation to this. Water from the release control ponds would be conveyed to the release point via a release channel. The release channel would consist of a gravity fed channel lined with rip rap to prevent erosion. Water would be released into Wheatley Creek over an embankment which would be flooded at high tide. Rip rap or a rock mattress will be placed will be placed up to the low tide mark to ensure no scouring of the salt flat.

The release control ponds would not be constructed until at least Stage 2 of the Project. Given the quantity of water to be discharged at Stage 1 (i.e. 2,200 m³/day), water would be released, via the release channel, from the settlement ponds. Stop logs would be installed on the settlement ponds to allow for the controlled release of waste water on the mid to high tide. Discharging on the mid to high tide allows for rapid dilution and dispersion of the waste water in Wheatley Creek, thereby mitigating potential impacts to water quality outside of the initial mixing zone.

The staged nature of the project will permit the gradual increase in discharge. Water quality monitoring will be undertaken over this time as a requirement of the waste discharge licence. This will permit an adaptive management approach to the discharge water and its subsequent release. The construction of the release control ponds in later stages of the Project will be determined through this process as well the storage capacity of the settlement ponds.



Project Description



Section 2.5.8


It is difficult to envisage from the draft EIS how the freshwater would be managed on-site to capture maximum rainfall supply during a dry year while using it for operation. Provide the calculations used to determine how much fresh water can be harvested and stored on site and demonstrate the limitations on storage capacity that would require the import of water.

Proponent Response

As discussed in Section 2.5.8, rainfall capture alone will not fully meet the freshwater demand of the CBC and BMC facilities during operation. As such, additional water will be required to be supplied by a suitably licenced operators.

The annual freshwater demand required by the CBC and BMC during operations is presented in Table 2-5. Water balance calculations have been undertaken to determine how much can be captured onsite and how much will be required to be sourced externally. Based on these calculations it is anticipated that 1,861 kL will be required to be sourced externally. In the event that there is a dry year and rainfall capture is less than anticipated, more freshwater can be imported to supplement supply. This is a project risk and therefore not a matter for the EIS.


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Project Description



Section 2.5.9


White spot disease, which has recently been the focus of an emergency response in southern Queensland, can be transferred to other prawns and vectors through contaminated water. Provide information on how contaminated water would be treated and disposed of in the case of a disease outbreak.

Ensiling was raised as an option in the NOI – provide confirmation that this option is no longer being considered for the management of biological waste.

Proponent Response

The matter of the risk of disease incursion and subsequent management has been discussed with the Department of Primary Industries and Resources. The NT EPA should be aware that there is a series of statutes and nationally agreed protocols that enter into force in such an event. The primary responsibility of the operator in the first instance is notify relevant authorities. In the case of the CBC and BMC at Bynoe Harbour the relevant authority is the Department of Primary Industries and Resources (NT).

The Northern Territory Government is a signatory to the Intergovernmental Agreement on Biosecurity, under which nationally agreed approaches are established and all jurisdictions have roles and responsibilities. The Commonwealth Biosecurity Act commenced in June 2016 as the primary piece of national biosecurity legislation. It is co-administered by the Ministers responsible for Agriculture and Water Resources and Health.

As already noted, in the event that a notifiable disease is confirmed the proponent is required to contact the authorities. In practice however, it is most likely that the authorities will have already been notified and they may have been included in verifying the pathogen, since typically government laboratories and agencies participate in the investigative phase.

The CBC and BMC is biosecure. This means that the operating context is not comparable to the situation in Queensland. For more information please see the following table that summarises, a few of the key strategies implemented to exclude pathogens.

TABLE 6 SUMMARY OF EXCLUSION PRACTICES INCORPORATED WITHIN THE DESIGN

Potential Vector Exclusion approach

Prawns for culture Prawns for culture are to be of known health status and specific pathogen free

Incoming water or animals (i.e. from environment) All water is filtered and ozonated to point of sterilisation.

Crabs and other crustaceans Fencing and surveillance.

Birds Culture occurs under cover no birds access.

Humans Authorisations, controlled access, biosecurity training, hand/foot sterilisation. Limited/no human movement between facilities.


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Potential Vector Exclusion approach

Vehicles Limited/controlled access, washdowns.

Disposal of mortalities Incineration proposed - otherwise offsite via contracted licenced operator.

In terms of disposal of contaminated water the short direct response to the Department's question is that the water will likely no longer be contaminated because it will have been treated to the satisfaction of authorities prior to release. The proponent notes that there is sufficient capacitance engineered within the system to manage the holding of water.

In the event that in-situ full tank/facility sterilisation were required it is likely that a number of options would be considered in terms of chemical treatment. These include chlorine or trichlorfon. The half-life of these chemicals is short and chemical testing would be deployed to ensure residues are not released to the environment. Sterilisation would be accompanied by microbiological testing.

There is a range of possibilities in relation to management of disease with an extraordinary number of variables to consider in order to inform evidence-based management of an outbreak. Such variables include (but are not limited to):

the pathogen (e.g. whether exotic or endemic, whether viral, bacterial or fungal);

the extent of the infection (e.g. number of tanks/raceways showing signs of stress);

the nature of the biosecurity breach;

the virulence of the infection;

the displayed symptoms;

environmental circumstances and context (e.g. outbreaks in the region etc).

Given the above, it is essential to respect and recognise Australia's well developed biosecurity framework which includes, legislation and the operation of the Aquavet Plan (see: http://www.agriculture.gov.au/animal/aquatic/aquavetplan) and a raft of other measures that include changes to translocation permits and the activation of expert groups. For example it may be deemed necessary to activate the Consultative Committee on Emergency Animal Disease (CCEAD) (see: http://www.agriculture.gov.au/animal/health/committees/ccead) under the intergovernmental Emergency Animal Disease response Agreement (see: https://www.animalhealthaustralia.com.au/what-we-do/emergency-animal-disease/ead-response-agreement/).

Ensiling is not proposed to be used.



Project Description



Figure 2-9


If appropriate, discuss the option of recirculating water from discharge water (settling) ponds back into breeding and broodstock systems.

http://www.agriculture.gov.au/animal/aquatic/aquavetplan

http://www.agriculture.gov.au/animal/health/committees/ccead


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Proponent Response

The option of recirculating water has been considered for the BMC and CBC facilities at Bynoe Harbour however is not considered to be commercially feasible at this time. Each area of the operations requires a highly biosecure water source to maintain the specific pathogen free status of the animals prior to introduction to the commercial facilities. This biosecurity is paramount and recirculating water would require at a minimum; filtration and ozone treatment so that it is sterile as well as nutrient removal. Given the volumes of water required by the CBC and BMC facilities, this would more than double the investment the proponent would need to make to meet its biosecurity objectives for water treatment. The proponent is however, actively looking at improving water handling processes as technology and operating processes evolve in the future.



Approval, Conditions and Outputs



Chapter 4


This section needs to be expanded to include the National Environment Protection Measures (NEPM) for the Movement of Controlled Waste and the National Pollutant Inventory (NPI) implemented through an Environment Protection Objective under the Waste Management and Pollution Control Act (WMPC Act).

Proponent Response

A specific reference to the NEPM standards has been included in the Waste Management Strategy in Appendix C9 to the draft EMP, as well as a section relating specifically to interstate transfers of waste. The updated version of the draft EMP can be found at Appendix B of this SEIS.

Seafarms will comply with and be bound by all legislative requirements in relation to waste, whether a specific Environmental Protection Objective or other legislative requirement. National Pollutant Inventory reporting will be undertaken where any threshold is exceeded, as defined by the Environment Protection (National Pollutant Inventory) Objective and the NPI NEPM.






Section 4.4.14


The draft EIS states that a licence to extract seawater is not required under the Act.

The Proponent is advised that a licence may be required to extract seawater.

Proponent Response

This was an error in the draft EIS. The proponent will obtain a licence under the Water Act to extract seawater from Bynoe Harbour.


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Section 4.5


The following relevant guidelines have not been listed and the proponent should be aware that these guidelines may be referred to when applying for a licence under the WMPC Act:

NT EPA Guideline For Disposal Of Waste By Incineration

NT EPA Guidelines On Mixing Zones

Victoria EPA Guidelines For Environmental Management Biosolids Land Application (NT EPA endorsed guideline)

NT EPA Guideline For The Preparation Of An Environmental Management Plan

NT EPA Noise Guidelines For Development Sites In The Northern Territory

NT EPA Guidelines To Prevent Pollution From Building Sites

NT EPA Guideline Noise Nuisance From Bird Scaring Devices

Proponent Response

Noted - no response required.



Environmental History and Ecologically Sustainable Development



Section 5.5 – Core Objectives


Intention to pursue accreditation to Aquaculture Stewardship Council (ASC).

The EIS should include information that explains the aspects of these codes and standards that will be incorporated into operations to ensure environmental sustainability and demonstrate how design and operation of the CBC and BMC will meet the requirements for accreditation from ASC.

Proponent Response

While the proponent intends to pursue accreditation from the Aquaculture Stewardship Council (ASC), it is important to note that there are potentially areas within the ASC that are internally inconsistent with Australia's laws and regulations. The ASC Shrimp Standard has been developed primarily for shrimp grow out and will need to be assessed carefully against the facilities for this proposal. There is a hatchery standard; however the proposed facility is not a hatchery. The Standard was also developed in the context of the existing shrimp aquaculture industry which is almost exclusively found in developing countries that do not always have the governance frameworks that operate in Australia.


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TABLE 7 ASPECTS OF THE ASC STANDARD THAT WILL BE INCORPORATED INTO OPERATIONS AT THE LEVEL OF CONFORMANCE TO PRINCIPLES

ASC Principle Likely Compliance Comment

Principle 1 - Comply with all applicable national and local laws and regulations

Comply The proponent will comply with all laws and regulations

Principle 2 - Site farms in environmentally suitable locations while conserving biodiversity and important natural ecosystems

Comply Formally assessed as part of EIS process. The proponent considers that it meets all five criteria within this principle

Principle 3 - Develop and operate farms with consideration for surrounding communities

Comply Social impact assessment as part of the EIS process.

Employment opportunities.

Principle 4 - Operate farms with responsible practices

Comply subject to conformance with Australian laws

This Principle addresses labour relations and employment.

Many of the criteria and practices referred to in the standard do not occur in Australia such as bonded labour, child labour etc. In other cases youth training programs may fall outside the design of the ASC criteria and may yet provide highly beneficial social outcomes.

Principle 5 - Manage shrimp health in a responsible manner

Comply -

Principle 6 - Manage broodstock origin, stock selection and effects of stock management

Comply The facilities at Bynoe Harbour are critical to enable Project Sea Dragon to comply with the criteria within this principle.

Principle 7 - Use resources in an environmentally efficient and responsible manner

Comply This will primarily be addressed through the secondary approvals and licencing process which addresses most of the criteria within this principle which are generally:

Feed inputs: traceability, origin and wild fish-derived inputs (AQIS)

GM (not contemplated in this project)

Effluent (Waste discharge licence)

Energy efficiency (auditing)

Wastes and hazardous materials (NT EPA licences).


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Risk Assessment



Table 6-5


Clearing of vegetation and construction works have been scheduled for dry season however impacts from dust emissions were indicated to be short term and minor due to significant rainfall events. Clarify this statement as this may have implications for dust suppression water supply.

Proponent Response

There is potential for impacts from dust emissions as a result of vegetation clearing and construction works during the dry season. As stated in Section 2.5.8, freshwater will be required during construction for use in the concrete batching plant, paving, dust suppression and potable water supply for workers. This water will be trucked to the site by a suitably licenced commercial supplier. As such, water supply for dust management has been factored to freshwater requirements for the construction phase of the Project.



Risk Assessment



Table 6-5


Adhere to buffer widths recommended by the NT Land Clearing Guidelines where possible, with regard to riparian vegetation in drainage lines.

Provide an indication of areas where it is not possible to adhere to recommended buffer widths.

Proponent Response

The amount of riparian and mangrove vegetation clearance proposed has been minimised to as low as is reasonably practicable through design, which explicitly sought to avoid riparian and intertidal areas to the greatest extent possible. Design has been such that the only two pieces of infrastructure that will directly impact upon the intertidal zone are the intake and outfall structures. By virtue of their necessary interface with the marine environment it is impossible to locate these outside of the intertidal zone. However, relative the size of the mangrove habitat in Bynoe Harbour (~24,000 ha), the impact to the mangrove community is very low, being 0.66 hectares, which equates to 0.002 % of the extent of this community in Bynoe Harbour.

In terms of riparian buffers, as can be seen from Figure 7, a minor drainage line does run through the south-western corner of the BMC. It is not expected that this would result in any significant impacts to downstream water quality. Construction will occur in the dry season when there would be no water within this section of the watercourse. As such there will be no construction impacts associated to this drainage line. Nor is the removal of this relatively small section expected to have significant impacts in the wet season.


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Flora and Fauna



Section 9.3.1


The draft EIS states that no seagrasses are known to occur in the proposed pipeline footprint and, as such, it is considered unlikely that construction would have any direct impacts on seagrass meadows. The proponent has not conducted physical surveys of the area and has not provided clear evidence from literature reviews to justify this statement. While the NT EPA doesn’t consider it necessary to conduct a physical habitat survey of Bynoe Harbour, benthic habitat characterisation needs to be undertaken using existing available data sources to demonstrate that the risks to listed marine species as a result of habitat loss or disturbance is low, particularly in the area of the discharge.

Proponent Response

As detailed in the response to Comment 5 of DENR's submission (Section 3.3.4), an extensive review of available data sources was undertaken to inform the draft EIS in order to characterise the marine environment surrounding the Project Area. This has been supplemented for this SEIS by a review of several studies recommended by DENR in their submission on the EIS, including seagrass and benthic habitat mapping of Bynoe Harbour (Section 3.3.4).

The seagrass and benthic habitat mapping for Bynoe Harbour is provided in Figure 3. This mapping indicates that benthic habitats in the vicinity of the intake and discharge points for the Project consists of intertidal areas. Smit et al. (2000) reported that seagrass beds were present in the intertidal–subtidal areas and in the very shallow subtidal areas of Bynoe Harbour, including patchy seagrass beds near Point Ceylon. The closest mapped seagrass beds, however, are located 16 km from the Project Area, to the north of Indian Island (Figure 3). Furthermore, Paspaley (pers. comm) has not observed any seagrass beds in the vicinity of their oyster leases, which are adjacent to the Project.

The proposed intake pipe for the Project is to be located in an area that is likely to be characterised by sand/gravel substrate. The substrate at the release point is likely to be more varied with a combination of rock, mud, clay and sand. This is supported by observations made by Smit et al. (2000) which indicate that substrates in the inner regions of Bynoe Harbour consist mainly of mud flats and sand flats with the occasional rocky outcrops and rocky/coral reef. Observations made by Water Technology (2015) at low tide at Point Ceylon near the location of the proposed intake pipe also support this assessment, for example, see Plate 1, below.


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FIGURE 7 RIPARIAN BUFFERS


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PLATE 1 ROCKY OUTCROP AND INTERTIDAL BED MATERIAL AT POINT CEYLON (WATER TECHNOLOGY 2015)

The benthic habitat directly affected by the Project will be restricted to the footprint of the seabed over which the seawater intake pipeline. This footprint will cover at maximum, an area of 2 ha - an allowance has been made for a footprint of 2000 m long x 10 m wide to allow for some flexibility in placement and pipe sizing, but the width of the piping infrastructure is likely to be 2-3 m wide and hence the footprint will be substantially less than 2 ha. It is expected that benthic habitats in this area will recover once the infrastructure has been installed. Therefore any potential direct impacts to benthic habitats and marine megafauna as a result of the construction of the intake pipeline are likely to be localised and temporary.

Benthic habitats may also potentially be indirectly impacted from changes in water quality resulting from nutrient discharges at the release point. Numerical modelling was used to assess the impact of the waste water discharged from the Project on water quality. The results of this modelling indicated that there would be a mixing zone in which there will be occasional exceedances of nutrient levels (namely phosphorus and nitrogen) above the guidelines. This mixing zone would be limited to 100 m either side of the release point. Outside of this mixing zone there would be no impact to water quality.

There may be some changes to benthic habitats and macroinvertebrate communities within the mixing zone as a result of increased nutrient levels. It is not considered, however, that this would have a significant impact on any listed marine species given the relatively small area to be affected. As shown in Figure 3, intertidal habitats such as those in Wheatley Creek are widespread within Bynoe Harbour. Furthermore, these habitats are not considered unique or critical to the survival of any threatened fauna.


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Flora and Fauna



Section 9.3.1


The EIS should include a statement regarding the use of pile driving for anchoring the seawater intake pipe. If there is potential for pile driving to be employed, as opposed to screw anchors for example, then the EIS needs to include management measures to minimise impacts to marine megafauna from underwater noise.

Proponent Response

As discussed in response to Comment 2 from the NT EPA (Section 3.14.2), no pile driving will be undertaken as part of the Project.



Groundwater and Freshwater Supply



Section 10.6


This comment comprises of four distinct issues which have been dealt with separately in the proponent's response.

The discharge water settlement ponds are unlikely to incur a major leak as they are lined with a HDPE liner.

Issue 1

While leakage from HDPE lined ponds is not expected, provide details on whether monitoring bores or a leakage detection system will be installed to account for potential impacts from mounding or liner damage.

Issue 2

If groundwater is quite shallow across the area (ranges from 3m at the northern extent to 11.5m in middle of site), discuss the likelihood of groundwater levels rising above lined containment structures and rupturing when ponds are drained.

Issue 3

Provide clarification of methods for removing sludge/sediment from ponds without damaging the liner.

Issue 4

Discuss the potential for groundwater aquifers to be impacted by the release of salt water along permeable channels through the terrestrial environment.

Proponent Response

Issue 1


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Monitoring bores and leak detection layers, such as those used in the uranium industry, are not proposed to be installed. The ponds will be instrumented for water levels and volume exchange and this instrumentation will be sufficient to monitor for leaks and unplanned losses. Additionally, the ponds will also be routinely drained and de-sludged. This involves drying the membrane liner, wherein inspection for damage to the liner will be carried out. If the liner is damaged or a leak is detected, the liner will be mended appropriately or the pond relined.

Issue 2

The ponds will be constructed by shallow excavation (approximately 0.5 - 0.75 m depth) and the elevation of the locally won earth to form bund walls. As such the ponds will not be deep, and therefore nowhere near the ground water table.

Issue 3

To remove sediment from the ponds, the ponds will be drained first and the sediment will be hosed into a sediment trap, where it is left to dry. Once dry it is removed using hand tools such as shovels, and is transported to the designated sediment storage area. The frequency of sludge and sediment removal will be planned such that there is only a thin layer of sludge. Once dry, the thin layer will be removed by hand tools, not earthmoving equipment, to protect the membrane liner. If the sludge and sediment cannot be solar dried then removal of wet sludge will be by small suction line and pump to a commercially available de-sludging truck, such as that used in septic tank maintenance.

Issue 4

As discussed in Section 2.5.4.1 of the draft EIS, the channels connecting the CBC and BMC, the discharge settlement ponds and the discharge point will all be lined with a HDPE liner. Therefore it highly unlikely that that the discharge water in the channels will impact groundwater.



Marine and Estuarine Water



Table 11-1 and elsewhere throughout the document


There are 10 references to Section ‘0’ in Chapter 11. There is no Section 0 in the draft EIS. This was likely to be an editorial error.

Proponent Response

This is an editorial error in the document. The references to Section 0 have been updated and revised version of Chapter 11 is included as Appendix A.






Section 11.5.3


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The EIS should clearly identify the expected quality and quantity of the discharge from the proposed activity. This should include concentrations, typical averages and worst-case values of all potential contaminants of concern, assuming the treatment technology is working effectively. The quantity of the discharge should be expressed as average, minimum and maximum daily discharge volume, as well as maximum hourly discharge rate.

Information on the wastewater discharge regime should be used to estimate resulting contaminant loads.

Proponent Response

Sections 11.5.3 and 11.5.5 in the draft EIS (and Section 3.5.2 in Appendix 17) identify the anticipated discharge quantity and quality from the Project at full operation. As described above in Section 2.14.4, this is expected to be up to 12,440m3/day, with discharge water quality similar to existing Seafarms operations at Cardwell, Queensland.

The Cardwell site has licence limits, and has achieved typical results as presented in Table 8 below (reproduced from Table 11-6 of the draft EIS).

TABLE 8 CARDWELL OPERATION DISCHARGE WATER QUALITY – LICENCE CONDITIONS AND ACTUAL PERFORMANCE

Condition Median 80th Percentile Maximum

Total Nitrogen (mg/L) Licence Conditions 2.0 2.5 5.0 Actual Performance 1.1 1.5 2.8 Total Phosphorus (mg/L) Licence Conditions 0.4 - 0.6 Actual Performance 0.08 0.11 0.2

Using the above expected discharge concentrations, and a full scale discharge volume of 12,440m3/day results in the following range in discharge loads as kg/day, showing the median results recorded at Cardwell (minimum), to the licence limit (worst case), and based on 11,000m3/day discharge.

Total Nitrogen – 12.1 to 55 kg/day

Total Phosphorous – 0.88 to 6.6 kg/day

The hourly discharge rate has been assumed at 0.12m3/s in the modelling conducted for the EIS (refer to page 44 in Appendix 17). Modelling was based upon a constant release, but this will not be the built scenario, as water will only be discharged on mid to high tide. Discharging on the mid to high tide will allow for rapid dilution and dispersion of the waste water in Wheatley Creek, thereby mitigating potential impacts to water quality outside of the initial mixing zone.






Section 11.5.6



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There is some confusion caused by changing terminology in this section e.g. discharge water ponds, release control ponds, discharge release ponds. Confirm that settlement and separation of solids, and dechlorination, would occur in discharge water ponds (settlement ponds) and not release control ponds prior to being discharged. Assuming contaminants report to the discharge water ponds (settlement ponds), provide clear justification that 60 hours of residence time is adequate to ensure the full breakdown of cleaning products that may report to these ponds e.g. chlorine and hydrochloric acid.

Describe how discharge waters in discharge water ponds and release ponds can be effectively managed through cascading overflows from one pond to the next in the event that freeboard is exceeded in an extreme rainfall event when it is expected that rainfall would most likely be affecting all ponds equally.

Proponent Response

The proponent confirms that settlement and separation of solids, and dechlorinating, would not occur in discharge water ponds (settlement ponds) nor the release control ponds prior to being discharged. Chlorine is only used in the tanks after cleaning. All water containing chlorine will be held within the facility until no free chlorine is detectable. The proponent also confirms that 60 hours' time of residence is sufficient to ensure this. See also response to Issue 2 in Section 2.14.5 above. No other cleaning products will be used (i.e. chlorine is the only cleaning/disinfecting product to be used).

See response to Section above in relation to the management of cascading flows and freeboard.






Section 11.5.7.2


The draft EIS states that during extreme storm events there is potential for water to pass directly across a portion of low lying land adjacent to the discharge point…could result in a short spike in concentration at Point 4.

Please explain this statement with a diagram of the discharge point.

Wet weather influences on discharge characteristics should be considered and the characteristics defined where applicable.

Proponent Response

The elevation of the land around the discharge point was to be determined during the hydrodynamic and water quality investigation. Conflicting survey results currently present different elevations of the open area of land west of the discharge point as shown in Figure 8.

Depending on the elevation of this land, during periods of high water – either from large spring tides, high storm tides or extreme water levels, there is potential for the transfer of water directly between Wheatley Creek and Geranium Channel as indicated by the arrows in Figure 8. The concentration of model tracer at Point 4 (see draft EIS Figure 11-24) may therefore vary from that indicated by the modelling. However, during these events the additional flow of “clean” water from Geranium Channel across this low lying land will increase the dilution of discharge within Wheatley Channel.


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The volume and duration of the flow connection between Geranium Channel and Wheatley Creek will be dependent upon the elevation of the land in this area, however, based upon the data collected from the survey events, may be as limited as a very short period occurring only at the very peak of the storm tide.

FIGURE 8 AREAS OF POTENTIAL HIGH WATER LEVEL FLOW CONNECTIVITY






Section 11.5.8


Additional treatment options will be implemented.

Provide information on the additional treatment options that may be considered and the criteria that would inform the decision to implement these options.

This comment also applies to Section 11.5.9 in relation to water quality deterioration from suspended solid loading.

Proponent Response

Potential additional options are included in the draft EIS. The submitter is directed to Appendix 16 'Request for Information Response 4' Section 1.4.


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In relation to Section 11.5.9 the proponent has undertaken to meet the Guidelines for Darwin Harbour which the NT EPA has accepted is appropriate (see Statement of Reasons). On a mass basis it is highly unlikely that there is sufficient source of sediment in the facility to provide loadings that would exceed the proposed limits.






Section 11.5.9


The draft EIS in its discussion of turbidity values appears to infer that the Bynoe Harbour system should be categorised under the ANZECC Guidelines as slightly to moderately disturbed estuarine waters. Provide a clear statement on the ecosystem protection level proposed to be applied to Bynoe Harbour. If the ‘slightly to moderately disturbed’ category is considered appropriate, provide justification.

Proponent Response

The Australian and New Zealand Guidelines for fresh and marine water quality (ANZECC & ARMCANZ 2000), often referred to as the Australian Water Quality Guidelines (AWQG) recognise 3 levels of ecosystem condition (Section 3.3.2.3, page 3.3-6 of the AWQG):

1. high conservation/ecological value (condition 1 ecosystems)

2. slightly or moderately disturbed (condition 2 ecosystems) and

3. highly disturbed (condition 3 ecosystems).

Bynoe Harbour has been classified as a slightly to moderately disturbed ecosystem. The definition (from the AWQG) for Condition 1 and Condition 2, and comments on the definitions with reference to the receiving environment are provided below.

Condition 1 Ecosystem

High conservation/ecological value systems — effectively unmodified or other highly-valued ecosystems, typically (but not always) occurring in national parks, conservation reserves or in remote and/or inaccessible locations. While there are no aquatic ecosystems in Australia and New Zealand that are entirely without some human influence, the ecological integrity of high conservation/ecological value systems is regarded as intact.

Condition 2 Ecosystem

Slightly to moderately disturbed systems — ecosystems in which aquatic biological diversity may have been adversely affected to a relatively small but measurable degree by human activity. The biological communities remain in a healthy condition and ecosystem integrity is largely retained. Typically, freshwater systems would have slightly to moderately cleared catchments and/or reasonably intact riparian vegetation; marine systems would have largely intact habitats and associated biological communities. Slightly–moderately disturbed systems could include rural streams receiving runoff from land disturbed to varying degrees by grazing or pastoralism, or marine ecosystems lying immediately adjacent to metropolitan areas.

The marine ecosystem of Bynoe Harbour is in a healthy condition and ecosystem integrity is largely retained. It has, however, been affected to some degree by human activity. The area surrounding Bynoe Harbour has been subject to development, mainly in the form of rural residential subdivisions and the construction of associated


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infrastructure required to service these subdivisions including roads and boat ramps. It is also, given its proximity to Darwin, a popular recreational fishing and boating area and the Paspaley Pearling Company runs a number of oyster leases in the harbour. As such, while the ecosystem is in healthy condition, it is not entirely without some human influence and therefore is considered to meet the definition for a condition 2 ecosystem.

Furthermore, there is a precedence for this classification, as the proposed Marine Harvest Barramundi Fish Farm at Port Paterson (located within Bynoe Harbour) compared the results of water quality sampling in Bynoe Harbour to the ANZECC guidelines for slightly to moderately disturbed ecosystems.






Section 11.5.10


Potential for chemicals to be used to control bacteria and pathogen vectors. Adherence to Code of Practice. Validated through continual monitoring.

Explain how these chemicals would be managed and monitored e.g. discharge water withheld even with a continuous release scenario, parameters to be monitored, etc.

No release which could harm the environment is planned, no risk to the flora or fauna of Wheatley Creek or adjacent Bynoe Harbour is considered likely from release of chemicals in water discharge.

Discuss the risks and potential impacts of an unplanned release.

Proponent Response

The proponent is unclear as to what to what comment is trying to investigate. The section of the draft EIS refers to says, 'in the unplanned event that chemical treatment is needed at the facility all waste waters will be tested to confirm adherence with release guidelines to manage risk of environmental impacts.'

In other words the event that is contemplated which is 'unplanned' is the use of an unforeseen (i.e. not routinely used) chemical, presumably in response to a government directive associated with a biosecurity incident.

The point at which waste water would be monitored will likely be in the final settlement/wastewater pond and/or the final retention pond. That is prior to release.

A continuous release scenario is not an 'uncontrolled' release scenario. As described in Section 11.5.2 of the draft EIS and in Sections 3.13.2 and 3.13.6 above, discharge will be controlled to release on the mid to high tide only. As such, the wastewater/settlement ponds have sufficient capacity to manage (and therefore stop) the release of water to the environment if necessary. Water can be held within tanks, exchanges can be reduced and, if necessary the intake of water can also be stopped. In fact as described in the draft EIS, part of the design is to be able to manage such that it is not necessary to intake water continuously.

As to what would be investigated (or monitored or assessed) would depend on the chemical that had been, or was being used. The current operational regulatory guidance which is the 'Operational Policy Marine Prawn Aquaculture - Licensing Wastewater Releases from Existing Marine Prawn Farms in Queensland' (Department of Environment and Heritage Protection, 2013) states:


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The only drugs and chemical substances allowed to be used in prawn farms are those authorised by the Australian Pesticides and Veterinary Medicines Authority (APVMA), prescribed by a veterinarian or those substances that have been declared "Exempt from Registration" and their use shall be in accordance with the label's requirements.

All drugs and chemicals authorised to be used at the facility shall only be discharged to the receiving environment at a level prescribed or authorised by the administering authority in accordance with ANZEEC Guidelines.

The proponent is not clear on what is meant by an 'unplanned' release; especially in the context of chemicals not routinely used. For example a sudden unexpected failure of one of the tanks in the CBC would lead to water being captured in within the drainage system and would not go to the environment. The ponds being constructed have a low hydrostatic head and are less likely to fail than the average Australian farm dam. Each of the wastewater/settlement ponds is capable of being contained.






Section 11.5.11


Routine monitoring will be undertaken to validate management measure effectiveness or provide opportunity for adaptive management if required.

Discuss the adaptive management options available for project waste water discharge if changes are required, including consideration of emergency releases.

Proponent Response

Section 11.6 of the draft EIS summarises the key controls in relation to discharges. It includes design and normal operational activities to manage discharges, and also the following adaptive options that could be adopted:

Staging water within release ponds for adequate time prior to release to enable dechlorination and settlement of suspended solids - i.e. effective whole of site water management

As technology improves, providing the ability in the facility design for discharge waters to be recycled within the production system, if required, to achieve improved water quality prior to discharge - i.e. additional internal recycling and treatment in existing systems where required

Additional controls given in the EIS in various locations, as well as other options which, in future with improved technology, can be considered include altered farm operations - improving feed conversion (FCR), more aeration (dissolved oxygen, reduce biochemical oxygen demand), alter water exchange rates and internal recycling.


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Section 11.7


The draft EIS states that prior to construction Seafarms propose to undertake an assessment of mangrove conditions and tidal vegetation along Wheatley Creek and an aquatic ecology survey (benthic macroinvertebrates and macroalgae). Requirements for subsequent ecological monitoring will be ascertained by results of monitoring of water quality parameters.

Discuss the parameters that are available and would be suitable for the robust measurement of potential impacts to the ecology of Wheatley Creek and Bynoe Harbour from wastewater discharge and how these could be included as part of the receiving environment water quality monitoring program. Measurement of biological parameters should be considered early to ensure a baseline is established prior to construction.

Water quality in macro tidal environments such as Bynoe Harbour is fundamentally influenced by tidal cycles. The apparent lack of measures in the receiving environment water quality program to account for tidal variation may diminish the utility of the current data set as the baseline for a before-after control-impact monitoring design. The EIS should:

characterise the nature of water quality variation in the receiving environment due to tidal variation

analyse relevant data to determine the most suitable method for standardising data collection methods to minimise the confounding effects of natural water quality variation due to tidal variation.

include an amended sampling program reflecting changes to improve the usefulness of future data collection for baseline and impact monitoring purposes.

Proponent Response

Appendix C7 of the draft EMP (see Appendix B) contains the monitoring framework for this baseline monitoring program, in particular in Table C7.4 and shown in Figure C7.1. This includes:

3 sites - Intake Point, Wheatley Creek and Near the confluence of Mackenzie Arm and Geranium Channel

Monthly sampling

Testing for:

Temperature, Dissolved Oxygen, Electrical Conductivity, pH and Oxidation Reduction Potential

Suspended Solids, Total Dissolved Solids, Total Organic Carbon

Nitrogen (Total Kjeldahl Nitrogen, Nitrate, Nitrite, Ammonia, Total Nitrogen), Phosphate, Filterable Reactive Phosphorus

Chlorophyll (a) and Turbidity

As noted in our response to the Department of Environment and Natural Resources Comments 3, 14, 16 and 17 (Sections 2.3.3, 2.3.14, 2.3.16 and 2.3.17), additional sites are being considered, and monitoring will include biological monitoring (macroinvertebrates and δ15N signatures from mangroves) and sediment sampling.


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The proponent has committed to the formulation of Water Quality Trigger or Guideline levels as part of the Water Quality Monitoring Program and as such has continued to collect water quality data to enable this to occur. Analysis of the data will also continue to include statistics such as the range, and 5th and 95th percentiles. The data will also be re-analysed to determine if there are any significant variations due to tide, lunar cycles or season, and trigger values established on that basis. Given the analysis to date, it is not anticipated that these trigger values will be significantly different from the proposed interim triggers, however, seasonal triggers may be appropriate for some parameters (e.g. turbidity). The most suitable times for data collection for the ongoing water quality monitoring program will be refined as further data is collected. The proponent anticipates that, moving forward, data collection will be standardised on the neap tides.



Waste Management



Chapter 12


The activity proposed is regulated under the WMPC Act. The following may be required as part of licence approvals:

1. Activities that require environment protection approval include -“Constructing, installing or carrying outworks in relation to premises, other than sewage treatment plants, for the storage, re-cycling, treatmentor disposal of listed wastes on a commercial or fee for service basis.”

2. Activities that require a licence –

collecting, transporting, storing, re-cycling, treating or disposing of a listed waste on a commercial or fee for service basis, other than in or for the purpose of a sewage treatment plant

operating premises, other than a sewage treatment plant, associated with collecting, transporting, storing, re-cycling, treating or disposing of a listed waste on a commercial or fee for service basis.

3. The proponent will be required to apply for the following:

an environment protection approval (EPA) for the construction of the project potentially including incinerator and waste transfer stations

an environment protection licence (EPL) for the ongoing operation of the incinerator facility

a Waste Discharge Licence for discharge of waste water from the ponds.

4. Information that will be required for assessment for the granting of an EPA and EPL will include but is notlimited to:

construction quality assurance plans

emergency response plan

design of incineration.


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Proponent Response

Noted - no response required.



Waste Management



Table 12-6


Concrete batching will be conducted on site. The management of waste products for concrete batching should be considered in respect of maximisation of reuse and recycling of the water and materials.

Proponent Response

It is considered that normal operating procedures will be adopted for any concrete batching operations, including maximising reuse and recycling of water and materials. Waste minimisation for concrete batching is listed in Section 12.4.2 of the draft EIS (repeated in Appendix C9 of the draft EMP - see Appendix B of this SEIS), however more generally Best Practice Environmental Management will be adopted, with reference to guidelines such as the Queensland Department of Environmental and Heritage Protection Code of practice for the concrete batching industry.



Waste Management



Section 12.4.7


The EIS states that sediments from water storage areas will be removed every 6 – 12 months and placed in dedicated areas in accordance with the Environmental Code of Practice for Australian Prawn Farmers.

Provide discussion on:

details of the drying area – location, volumes of sediment it will contain, preparation of base

the expected volumes of water that could be directed back into the ponds from the drying pad during a Wet season and how this could affect the water balance of the ponds (presumably the ponds would be cleaned in the Dry season)

operational practices for the management of this material to minimise any impact to the surrounding environment including groundwater or soil through the leaching of salts and nutrients

the suitability of the dried solid waste as a fertiliser when spread on local native vegetation, and the potential for longer term changes to soil structure, vegetation, and for surface and groundwater contamination

how this waste water drying area meets requirements of the Victoria EPA Guidelines for Environmental Management of Biosolids Land Application (NT EPA endorsed) and comparison of these requirements with those of the Code of Practice for Australian Prawn Farmers for managing sediment.


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Proponent Response

The drying area will nominally be a 35 m square designated pad adjacent to each group of settlement ponds (see Section 12.4.7 of the draft EIS). The area will be bunded with local earth, with a clay base and walls, for retention of sediment and water, and to avoid leakage to soils and groundwater. Stormwater from these pads will be directed to the first settlement pond to ensure no release of nutrients or other contaminants without treatment.

In terms of expected volumes of water that could be directed back into the ponds from the drying pad, the 35 x 35 m (1,225 m2) drying pad represents only a small percentage of the settlement pond surface area, with a consequently low additional water source to these ponds in major rainfall events. To put this into perspective, a 1 in 100yr 24 hour event at ~350mm would result in a 430kL water addition to the pad. This would represent ~1% of the total volume of the ponds for a 35 x 35 m drying pad, easily handled by the combined system. Note the 500mm freeboard would not be exceeded by this event.

The quantity of material is anticipated at ~150kg, or ~0.13m3 per raceway per year (on a dry basis). This equates to approximately 48t or 38m3 per year.

This material is to be solar dried and aerated in the designated area. Once leached of salt (the material will be spread in thin layers <1m depth in any season, suitable for flushing of salts over a small number of wet seasons), this material, with its high levels of organic material, can be used to help revegetate pond and channel banks. This will be in accordance with relevant guidelines and standards, with the intent to comply with the Environmental Code of Practice for Australian Prawn Farmers requirements (Donovan, 2001, pp19-20). The material will not be added in such a way as to cause soil decline (structural, salinity or nutrient related) in any area.

In terms of biosolids, the Victoria EPA Guidelines for Environmental Management of Biosolids Land Application are related to sewage biosolids, and the stabilisation times in that document related to pathogens for health and safety. This will not be required for the pond waste material. In terms of nutrient addition to soils, the NLAR (Nutrient Limited Application Rate) will be considered in any land application (as well as the CLAR, the Contaminant Limited Application Rate where necessary). This considers the application rates, concentration of constituents including nutrients, and plant uptake. Thus its use as a fertilised soil medium will be in the context of the soil-plant system and long term sustainable use.



Waste Management



Table 12-10


Provide details on whether the Proponent intends to operate a landfill on site.

Proponent Response

As noted in Section 12.4.3 of the draft EIS, no landfill will be operated on the site.



Air Quality and Noise


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Figure 13-1


Clarify that the proposed incinerator is co-located with the power facility.

Provide a figure showing distances to boundaries of properties and nearest off-site sensitive receptor/s.

Proponent Response

The proposed incinerator will be co-located with the power facility (see Figure 9). The nearest offsite sensitive receptors are located in the rural residential subdivision of Dundee Downs, approximately 3 km to the south-west of the proposed power facility and incinerator.






Section 13.2


The Proponent should be aware that emissions from the power facility and incinerator may have reporting requirements under the Environment Protection (National Pollutant Inventory) Objective.

Discuss the potential for odour impacts at nearest off-site sensitive receptor/s

Proponent Response

Noted, and reporting will be undertaken should the facility exceed the relevant thresholds.

Odour is not anticipated to be an issue for the Project, since the nearest sensitive receivers are far removed from any potentially odorous elements. As reported in Section 12.4.5 of the draft EIS, there will be no detectable smoke or odour emissions under the standard operating conditions in which the incinerator will operate. The accommodation village will be the closest sensitive receiver, though located on the site, and this will be located at a substantial distance from the BMC, CBC and any discharge / settlement ponds or pond waste areas.






Section 13.3.3


Preliminary noise model to gain understanding of noise levels at accommodation village.

Discuss predicted noise levels at the property boundary and nearest off-site sensitive receptor/s.

Proponent Response

As discussed in Section 13.3 and shown in figure 13-2 in the draft EIS, the acceptable noise criteria contours from the power station (the loudest noise source in the Project) are met well within the site boundary.


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FIGURE 9 POWER FACILITY AND INCINERATOR LOCATION


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Figure 13-2


Power facility and incinerator moved 520m south.

Provide a figure showing the new location of the power facility and incinerator

Proponent Response

It was recommended in the draft EIS that the power facility and incinerator be moved 520 m south to achieve both noise and air quality outcomes at the accommodation facilities. Following further design, the power station was sited 1 km to the north-west of the original location. This was done to centralise infrastructure and minimise the cable runs as well as utilise flatter land to the north of the site. The new location of the power facility and incinerator is shown on Figure 9 above.

Given the separation distance (i.e. approximately 1 km, double the distance recommended in the draft EIS), the risk of any noise and air emission impacts from the power facility and incinerator at the accommodation village is assessed as very low.






Section 13.4.2


Arsenic and mercury that may be found in prawn carcasses.

Discuss how arsenic and mercury becomes present in prawn carcasses and the predicted concentrations in air emissions.

Proponent Response

Arsenic and mercury may become present in prawns either through absorption or dietary exposure. Both mercury and arsenic naturally occur in low levels in the environment, however much of the mercury and arsenic that finds its way into seafood is from contamination from anthropogenic sources including from coal burning power plants and mining.

Arsenic and mercury will not be present in the prawns from the CBC and BMC. The Project is not located near any land uses that may be a potential sources of mercury or arsenic contamination. Additionally, the feed used at the CBC and BMC will be sustainably sourced and compliant with the ASC so will not contain arsenic and/or mercury. Therefore no arsenic and mercury emissions are anticipated from the burning of prawn carcasses in the incinerator.

Note also that incineration is only an option at this stage, the other option for disposal of biological waste is offsite disposal by licensed transports to licensed facilities.


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3.15 POWER AND WATER CORPORATION





-


In reference to sourcing and transportation of freshwater (potable water) to site, Power and Water notes that the proposed development site is located approximately 10 km from the nearest suitable reticulated water network. The developer can obtain their freshwater requirements from the water filling station located at the Darwin River Dam entrance. Please see the attached map.

Proponent Response

Noted. As discussed in Section 2.5.8 of the Project Overview, potable water will be sourced from a suitably licenced commercial supplier. The licenced commercial supplier will source potable water from a suitable source.

3.16 R.A. WHITE A submission from a member of the general public, R.A. White was received on the 8 December 2016. Included as an attachment and referenced throughout the submission was a previous submission made to the Pastoral Land Board on the Non-Pastoral Use Application for the Grow-out Facility on Legune Station. While the comments from this submission (Comments 10 to 12) have been included for completeness, it is important to


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note that the Non-Pastoral Use Application for the Grow-out Facility on Legune Station is an independent assessment process to the EIS for the CBC and BMC and therefore is not required to be addressed in this supplementary EIS.


Chapter -



-


As Legune Station between Keep River and Victoria River will be the proposed grow out location I question here why the applicants also require this land in Bynoe Harbour when they contend they have sufficient land on Legune?

Proponent Response

The breeding facilities (i.e. the CBC and BMC and Hatchery) are required to be geographically separate from the Grow-out Centre on Legune Station for a number of reasons. Firstly, the breeding facilities require seawater that maintains relatively uniform salinity year-round. Salinity levels in the waterways around Legune Station fluctuate as a result of large freshwater inflows during the wet season and are therefore not suitable for the breeding facilities. Secondly, the breeding facilities are required to be geographically separate for biosecurity purposes. Having the facilities in separate locations minimises the risk of cross-contamination should a disease outbreak occur.

As such, the CBC and BMC have been located at Bynoe Harbour and the Hatchery will be located at location in the Darwin environs away from the grow-out facility on Legune Station.


Chapter Flora and Fauna



-


It is beyond comprehension that they would be allowed to threaten and pollute two pristine areas of the Territory. Both Legune and Bynoe are pristine areas and free from damaging unfettered development. Both have an endemic social network that is special to the fauna that permanently reside or come and go on foraging trips throughout the years. Eg Pelicans that originate from just inside the WA border Island (Pelican Island) do an annual visit to the Grose Island group and Bynoe and I have seen them further east at Port Essington and other locations. Australia does not have a good record with our flora and fauna protection with many species now extinct and the endangered list is continually growing.

Proponent Response

As discussed in the response to Comment 24 of the NT EPA's submission, the estuarine waters of Bynoe Harbour are not considered pristine (i.e. classified as high conservation/ecological value under the ANZECC guidelines) as they are subject to some human influence. The catchment area surrounding Bynoe Harbour has been modified by residential subdivisions and associated infrastructure (e.g. roads) and Bynoe Harbour and adjacent waterways are frequently used by commercial and recreational fishers. Paspaley Pearling Company


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also operates a number of commercial oyster leases in Bynoe Harbour. The draft EIS has demonstrated that the project will not result in any significant impacts to the water quality, or the flora and fauna of Bynoe Harbour.

An assessment of potential impacts to marine and terrestrial fauna including both threatened and migratory fauna listed under the EPBC Act and TPWC Act was undertaken as part of the NOI and EIS. Based on this assessment, the development of the Project will not have a significant impact on any threatened and migratory fauna, either terrestrial or marine.


Chapter Flora and Fauna



-


Should the Legune site be approved it will be an ecological disaster unless stringent conditions are fixed in place to protect and safeguard the flora/fauna of the Legune area and these same conditions if applied to this small area in Bynoe would preclude and deny any damaging development to this fragile eco system. I would certainly recommend that two aerial tours be made by decisions makers at both high water and low water to bring this point home.

Proponent Response

This comment appears to be addressed to the NT EPA and is not a matter for the proponent to address in the EIS.


Chapter -



-


In my submission below to the Pastoral Land Board I question the probity of the applicants and their financial capability (and lodgement of non-refundable cash bond to rectify and restore the land to it’s original condition) and attached are some press blurbs by lobbyists and promoters. I would draw your attention to a detailed article in The Weekend Aust of 15/4/2016 and the interesting information therein –Seafarms fast-tracks $1.5bn NT prawn farm to lure foreign investors by Sue Neales, rural reporter. There is a lot of ‘jumping the gun’ going on behind the Political scenes and yet the basics are still not in place. Hopefully they will not be flippantly dismissed and bulldozed out of the way. This would not be in the public interest.

Proponent Response

This comment is not a matter for the EIS.


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Chapter Other



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A baseline study has to be done as in my prior submission and not on reports and/or assessments from paid consultants, scientists and the like who are paid by the project promoters. Any study has to be independently evaluated.

Proponent Response

The EIS has been prepared and submitted by the Proponent as is required by the EA Act. As detailed in Appendix 4 (EIS Team), consultants from a number of independent, highly experienced and reputable consultancy organisations were contracted to prepare the technical reports that underpin the EIS. It is then the role of the NT EPA to independently assess and evaluate the EIS.


Chapter -



-


Safety to the local prawn and fishery industry has to be paramount. Prawns will escape into the wild and very stringent safeguards are required to be in place. Prawn farming in Australia is an inexact process so far (10 years?) and under close study by CSIRO and Uni groups so we do not have the Mekong Delta pollution of Vietnam and Thailand’s problems visited upon us here. A question here, will broodstock be imported from Cardwell Qld or Exmouth WA into the NT or will only locally caught broodstock be used to protect our fragile environment?

Proponent Response

Prawn farming in Australia began in the 1980's and has and continues to be subject to strict environmental regulation.

As described in Section 2.9.3 of the Project Overview, the likelihood of accidental escape of prawns from the Project facilities is very low. To prevent the accidental escape of prawns, appropriately sized filters will be placed over all outlets to the settlement ponds. In the unlikely event that prawns should escape, the channel that leads to the release point presents a harsh environment in which any prawns are unlikely to survive.

It also should be noted that the prawns bred in the CBC and BMC will be black tiger prawns (Penaeus monodon) which are endemic to waters off Northern Australia. The founder stock which will be used to establish the breeding program for the Project will be sourced from wild populations of black tiger prawns from the waters around the Northern Territory and Western Australia. Therefore, whilst it is considered unlikely that any prawns will escape the CBC and BMC, any escape would be unlikely to significantly alter the ecology of surrounding estuarine environment.


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Chapter Other



-


Has the Qld Cardwell site been checked for problems?

Has the WA Exmouth site and procedures been checked for problems?

Proponent Response

These are not matters for the EIS.


Chapter Other



-


What protocols will be put in place to protect any wildlife incursions that will occur? Penalties? for non-compliance and not just token dollar amounts.

Proponent Response

The draft Environmental Management Plan for the Project contains a Fauna Management Strategy which outlines protocols for dealing with fauna interactions with the Project. Penalties for non-compliance are not a matter for the proponent to address in the EIS.


Chapter Other



-


Finally I would advise caution with the numbers and figures thrown about as estimates in the publicity stories as most of them are just telephone numbers and reality will prove to be quite different. There are a lot of unknowns in the proposals, eg What type of transport system and safeguards from Bynoe to Legune? Road, air or sea?, and a host of development problems that have not been addressed.

Proponent Response

It is unclear in the submission what "development problems" have not been addressed. Therefore the proponent is unable to respond to this comment.


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Chapter Other - Non-Pastoral Use Application for Legune Station



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Has a baseline study been conducted and recorded of all Fauna, Flora, Annual wet season ponding areas, improved and natural pasture areas to aid in rehabilitation should the project fail? (Territorians are regularly reminded of the failed Territory Rice Humpty Doo Project that Sir William Gunn and his cohorts abandoned to feral pigs, crocs and nature to reclaim on the Adelaide River Plains and the broad acre Sorghum disaster of Tipperary Station that now is the cause of annual flooding of the Daly River Road at Backyard Ck crossing. You could lump all the abandoned ‘Blue Sky Dreaming’ mines around the Territory into this equation as well.)

Proponent Response

This submission relates to the Non-Pastoral Use Application for the Stage 1 Legune Grow-out Facility on Legune Station. The Non-Pastoral Use Application for the Grow-out Facility on Legune Station is an independent assessment process to the EIS for the CBC and BMC and therefore is not a matter for this supplementary EIS.





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Are Project Sea Dragon and/or Seafarm Group viable accountable entities and not just front Companies. If they are operational companies then who are the ‘principals’ of their holding company? Have they lodged a non-refundable cash bond to the NTG to cover all future remedial works in case of failure of the project? A question here that stands out like the proverbial are they the owners of Legune Pastoral Lease or are they a lessee or sub-lessee and if the latter category are they legally able to apply for a lease variation without lodging a sizeable bond to rectify all proposed and future changes to this pristine landscape.( I note her that $80M of Territorians taxpayers money will be spent on a sealed bitumen pavement to Kununurra. This has been fast tracked while many rural regional NT residents still drive on dirt pavements after waiting ‘patiently’ for over 4 decades.)

Proponent Response

This submission relates to the Non-Pastoral Use Application for the Stage 1 Legune Grow-out Facility on Legune Station. The Non-Pastoral Use Application for the Grow-out Facility on Legune Station is an independent assessment process to the EIS for the CBC and BMC and therefore is not a matter to be addressed in this supplementary EIS.


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This application has far too many loose ends to be tied up that preclude any hasty decision despite all the media pressure that has been intense since August. The old political idiom applies here – Approve in haste, repent at leisure. (I question the retired Federal Trade Minister Andrew Robb’s ethics and involvement so ‘early’ in proceedings. There is no end of political heavyweight involvement- WA, NT and Federal as well as Indigenous Land Councils, NTEPA and other NTG agencies to collate.

Proponent Response

This submission relates to the Non-Pastoral Use Application for the Stage 1 Legune Grow-out Facility on Legune Station. The Non-Pastoral Use Application for the Grow-out Facility on Legune Station is an independent assessment process to the EIS for the CBC and BMC and therefore is not a matter to be addressed in this supplementary EIS.

3.17 UNIVERSITY OF TECHNOLOGY SYDNEY

3.17.1 Comment 1 Submitter Type University TOR Category or EIS




Section 5.5, Alternative Feed Type


Project Seagrass Dragon should be commended for their well-presented and considered Environmental Impact Statement.

Proponent Response






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We would like to provide some comments on their feed selection. Firstly, the proponents should be congratulated for using the CSIRO-developed NovacQ; this shows the company’s willingness to support ecologically sustainable aquaculture practices. The proponents mention that they have considered alternate feed types (page 10), yet to achieve an environmentally sustainable culture process, they will need to adopt


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some novel solutions which are likely to include microalgae-based feeds to provide suitable nutritional support for prawn growth.

Proponent Response

Noted. A number of alternative feed types were considered including NovacQ. These products are at differing stages of development and are not yet commercially available.





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Have the proponents consider the sustainability of their pelletized prawn food? The proponents are using locally grown algae to feed first stage naupilus as well as using Chaetoceros to feed to Artemia; could their expertise in this area be extended to the production of pelletized feed? This would show global leadership if Australia’s largest prawn producer could us clean/green sourced commercial pelletized feed.

We hope these comments assist the ecologically sustainability of this project.

Proponent Response

Some of the above comments are factually inaccurate. Chaetoceros is fed to the zoea (larval stage prawns) as a first feed type (not nauplii - these have a yolk sack and as such do not feed externally), artificial feeds are introduced at Mysis stages and continue onto pellets at the post larval (PL) stage. Cahaetoceros is not fed to Artemia as they are no enriched for prawn aquaculture (as they are in fish hatcheries).

All feed after PL stages will be pelletised for the growth stages and then natural feeds will then be reintroduced as a part of preparation for spawning.

The proponents have considered the sustainability of pelletised food and the EIS refers to the company's sustainable sourcing policy. The proponent is not a feed supplier.


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4 REFERENCES

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Australian and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand (2000) Australian and New Zealand guidelines for fresh and marine water quality, National Water Quality Management Strategy, Australian and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand.

Brocklehurst, P. and Edmeades, B. (2003) Mangrove Survey of Bynoe Harbour Northern Territory. Department of Infrastructure Planning and Environment, Northern Territory. Palmerston.

Brooks, L. and Pollock, K. (2015) The Darwin dolphin monitoring program: abundance, apparent survival, movements and habitat use of Humpback, Bottlenose and Snubfin dolphins in the Darwin area. Report to INPEX, document number L384-AH-REP-10012_0

Burford, M. A., Jackson, C. J. & Preston, N. P. (2001) Reducing nitrogen waste from shrimp farming: An Integrated Approach. In: The New Wave, Proceedings of the Special Session on Sustainable Shrimp Culture, Aquaculture 2001 eds C. L. Browdy and D. E. Jory, pp 35-43. The World Aquaculture Society, Baton Rouge, USA.

Cardno (2015a) Turtle and dugong monitoring post-dredging report: Ichthys Nearshore Environmental Monitoring Program. Report to INPEX, document number L384-AWREP-10250

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Chatto, R. and Baker, B. (2008). The distribution and status of marine turtle nesting in the Northern Territory. Technical Report No. 77, Parks and Wildlife Service of the Northern Territory.

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Chatto, R. (2006) The distribution and status of waterbirds around the coast and coastal wetlands of the Northern Territory. Parks and Wildlife Commission of the Northern Territory.

Chatto, R. and Warnecke, R.M. (2000). Records of cetacean strandings in the Northern Territory of Australia. The Beagle 16: 163-175.

Davies-Colley R.J. and Smith D.G. (2002) Turbidity suspended sediment and water clarity: a review. Journal of the American Water Resources Association 37: 1085 - 1101.

Department of Environment and Heritage Protection (2013) Operational Policy Marine Prawn Aquaculture - Licensing Wastewater Releases from Existing Marine Prawn Farms in Queensland.

Department of Health and Families 2011, Guidelines for preventing mosquito breeding associated with construction practice near tidal areas in the NT, Medical Entomology Branch Centre for Disease Control Department of Health and Families Northern Territory Government Darwin NT June 1988 Updated February 2011. Available from: http://www.health.nt.gov.au/library/scripts/objectifyMedia.aspx?file=pdf/32/37.pdfandsiteID=.

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Department of Health and Families 2006, Guidelines for preventing mosquito breeding sites associated with aquaculture developments in the NT, Medical Entomology Branch Centre for Disease Control Department of Health and Families Northern Territory Government Darwin NT February 2006. Available from: http://www.health.nt.gov.au/library/scripts/objectifyMedia.aspx?file=pdf/32/43.pdfandsiteID=1andstr_title=Guidelines%20for%20preventing%20mosquito%20breeding%20sites%20with%20aqua%20culture%20developments.pdf.

Department of Land Resource Management (2015) Department of Land Resource Management – NT Fauna Observations. Viewed online 1 December 2015 at http://www.lrm.nt.gov.au/plants-and-animals/informationand-publications/nt-fauna-observations

Department of Natural Resources, Environment, the Arts and Sport (2010) Land Clearing Guidelines. Technical Report No. 20 / 2009D

Department of Primary Industries and Fisheries (2016) Australian Prawn Farming Manual. Department of Primary Industries and Fisheries, State of Queensland.

EcOz (2003) Point Ceylon Aquaculture Project. Point Ceylon, Bynoe Harbour, Northern Territory Environmental Risk Assessment. Prepared for Suntay Aquaculture.

Environment Australia (1998) Interim Marine and Coastal Regionalisation for Australia: an ecosystem-based classification for marine and coastal environments. Version 3.3. Environment Australia, Commonwealth Department of the Environment.

Enesar (2006), Draft EIS–Proposed Barramundi Fish Farm at Port Patterson, Northern Territory, Prepared for Marine Harvest.

Jackson, C.J., Preston, N.P., Burford, M.A. & Thompson, P. (2003) Managing the development of sustainable shrimp farming in Australia: the role of sedimentation ponds in treatment of farm discharge water. Aquaculture 226: 23-34.

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Lin, H.P, G. Charmantier, P. Thuet and J.P. Trilles (1992). Effects of turbidity on survival, osmoregulation and gill NA+-K+ ATPase in juvenile shrimp Penaeus japonicus. Marine Ecology Progress Series 90: 331-37.

Roelofs, A., Coles, R., and Smit, N. (2005) A survey of intertidal seagrass from Van Dieman Gulf to Castlereagh Bay, Northern Territory, and from Gove to Horn Island, Queensland. Report to the National Oceans Office, Department of Environment and Heritage.

Smit, N., Billyard, R. and Ferns, L. (2000) Beagle Gulf Benthic Survey: Characterisation of soft substrates. Technical Report No. 66, Parks and Wildlife Commission of the Northern Territory.

Tover, A., C. Moreno, M.P. Manuel-Vez and M. Garcia-Varga (2000), Environmental implications of intensive marine aquaculture in earthen ponds. Marine Ecology Progress Series 40: 981-988.

United Kingdom Environment Agency (1998) Quality Control Manual for Computational Estuarine Modelling. Technical Report W168, Bristol United Kingdom

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APPENDIX A UPDATED CHAPTER 11


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APPENDIX B UPDATED DRAFT EMP

project sea dragon - ntepa

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