statement of environmental objectives: production and...

South Australia Cooper Basin Joint Venture

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October 2003

South Australia Cooper Basin Joint Venture Production and Processing Operations Statement of Environmental Objectives

Production and Processing SEO (October 2003)

Santos Ltd Statement of Environmental Objectives: Production and Production and Processing Operations

South Australia Cooper Basin Joint Venture October 2003 (First submission to PIRSA) Second Draft - February 2003 First Draft - 2001 © Santos Ltd ABN 80 007 550 923 91 King William Street Adelaide South Australia 5000

1st Draft by Susie Smith

Ecos Consulting (Aust) Pty Ltd 26 Greenhill Road Wayville SA 5034

Revised & Edited by Stewart Duncan

Corporate Environmental Adviser Environmental, Health & Safety Department

John Hudson Manager Administration Central Business Unit


Production and Processing SEO (October 2003) i

Contents

1 Introduction ........................................................................................................1

1.1 Purpose .............................................................................................1 1.2 Scope.................................................................................................1

2 Environmental Objectives ...................................................................................5

2.1 Objectives .........................................................................................5 2.2 Assessment Criteria ..........................................................................6

3 Reporting .......................................................................................................... 19

3.1 Serious Incidents.............................................................................19 3.2 Reportable Incidents.......................................................................20

4 Consultation...................................................................................................... 21

5 References & Further Reading.......................................................................... 21

Tables

Table 2-1: Environmental Objectives and Assessment Criteria ................................. 7

Appendices

Appendix 1 Environmental Hazards and Potential Consequences

Appendix 2 Criteria for Assessing Production and Processing Operations

Appendix 3 Criteria for Assessing Right-of-Way (ROW) Rehabilitation

Appendix 4 Criteria for Assessing Borrow Pit Construction and Rehabilitation

Appendix 5 Criteria for Assessing Produced Formation Water (PFW) Disposal – Field Inspections

Appendix 6 Criteria for Assessing Produced Formation Water (PFW) Disposal – Desk Audit

Appendix 7 Criteria for Assessing Oil Spill Remediation/Rehabilitation

Appendix 8 Overview of Stakeholder Consultation Process

Appendix 9 Stakeholder Comments and Responses


Production and Processing SEO (October 2003) ii

List of Abbreviations CBU Central Australian Business Unit

DOSAA Department of State Aboriginal Affairs

DST Drill stem test.

EIR Environmental Impact Report prepared in accordance with Section 97 of the Petroleum Act 2000 and Regulation 10.

EPA Environment Protection Authority.

EPBC Environment Protection and Biodiversity Conservation (Act 1999)

GAB Great artesian basin

GAS Goal attainment scaling

KPI Key performance indicator

NASAA National Association Sustainable Agriculture Australia

NEPM National Environment Protection Measures (Assessment of Contaminated Sites)

OBE Organic Beef Exporters

PEL Petroleum exploration licence

PFW Produced Formation Water

PIRSA Primary Industries and Resources South Australia

PPL Petroleum production licence

ROW Right-of-way

SACB South Australian Cooper Basin (Operators)

SACBJV South Australian Cooper Basin Joint Venture

SACOME South Australian Chamber of Mines and Energy

SEO Statement of Environmental Objectives prepared in accordance with Section 99 and 100 of the Petroleum Act 2000 and Regulations 12 and 13.

SHI Soil Health Index study.

LTU Land Treatment Unit


Production and Processing SEO (October 2003) 1

1 Introduction

1.1 Purpose

This Statement of Environmental Objectives (SEO) has been prepared to meet the requirements of Sections 99 and 100 of the South Australian Petroleum Act 2000 (the Act) and Regulations 12 and 13 of the Petroleum Regulations 2000.

The intent of this SEO is to outline the environmental objectives that the South Australia Cooper Basin Joint Venture’s (SACBJV) production and processing operations (referred to throughout as operation/s) are required to achieve and the criteria upon which objectives are to be assessed. Environmental objectives have been developed on the basis of information provided in the Environmental Impact Report (EIR) for Production and Processing Operations in the South Australian section of the Cooper Basin (SACBJV 2003).

The Petroleum Act broadly defines the environment to include natural, social, cultural and economic aspects. The environmental objectives outlined in the SEO incorporate all of these elements.

1.2 Scope

The Santos Central Australian Business Unit (CBU) operates the Moomba processing plant and associated facilities on behalf of the 11 companies that comprise the SACBJV. Santos is the designated Operator for all activities conducted pursuant to the South Australian Petroleum Act 2000 within the 160 Petroleum Production Licences (PPLs 6 to 167 inclusive but excluding PPLs 21 and 62 within the South Australian sector of the Cooper Basin). The CBU is responsible for undertaking all operations within these PPLs.

This SEO applies to all SACBJV production and processing operations in the South Australian sector of the Cooper and Eromanga basins (Figure 1-1). Operations that are covered by this SEO are:

pipeline, trunkline and flowline construction, operation and abandonment; plant and satellite construction, operation, maintenance and abandonment; produced formation water disposal operations; road construction, maintenance and restoration; waste management operations; Moomba airport operations; and fire training.

These operations are described in detail in the EIR (SACBJV 2003).



Activities associated with operations in the South Australian section of the Cooper Basin that are not discussed in the production and processing EIR or SEO are: exploration activities; drilling activities; sub-surface well/reservoir activities; well site and access track construction; drilling; well completion; pre-wellhead production; down hole abandonment; restoration of well sites and access tracks; and seismic operations.

These are covered in two separate SEO’s, being: Statement of Environmental Objectives for Seismic Operations in the Cooper and

Eromanga Basins, South Australia (PIRSA 1998); and Statement of Environmental Objectives for Drilling and Well Operations in the

Cooper/Eromanga Basin, South Australia (PIRSA 2000).

In addition to the activities listed above the EIR and SEO does not cover sales gas pipelines or the liquids pipeline to Port Bonython. These are addressed in separate EIR’s and SEO’s.



Figure 1-1: SACBJV production and processing facilities in the South Australian sector of the Cooper Basin



2 Environmental Objectives

2.1 Objectives

The objects of the Petroleum Act 2000 for Production and Processing Operations, include: to minimise environmental damage from activities involved in exploration for, or the

recovery or commercial utilization of, petroleum and other resources; and to minimise environmental damage from activities involved in the construction or

operation of transmission pipelines for transporting petroleum and other substances.

Potential hazards and consequences associated with SACBJV operations in the Cooper Basin were identified in the EIR (SACBJV 2003) and are summarised in Appendix A. The SACBJV is committed to achieving a range of environmental objectives with respect to these potential hazards and consequences and which are in keeping with the above objects of the Act. Environmental objectives for production and processing operations are presented below.

1. Minimise the risk to the public and other third parties.

2. Minimise disturbance and avoiding contamination to soil.

3. Avoid the introduction or spread of pest plants and animals and implement control measures as necessary.

4. Minimise disturbance to drainage patterns and avoid contamination of surface waters and shallow groundwater resources.

5. Avoid disturbance to sites of known cultural and heritage significance.

6. Minimise loss of aquifer pressure and avoid aquifer contamination.

7. Minimise disturbance to native vegetation and native fauna.

8. Minimise air pollution and greenhouse gas emissions.

9. Maintain and enhance partnerships with the Cooper Basin community.

10. Avoid or minimise disturbance to stakeholders and/or associated infrastructure.

11. Optimise waste reduction and recovery.

12. Remediate and rehabilitate operational areas to agreed standards.

13. Minimise as far as reasonably practicable interruptions to natural gas supply.



2.2 Assessment Criteria

The criteria for measuring the achievement of the environmental objectives are detailed in Table 2-1 and take one of the following forms:

Defined conditions - In some cases, the achievement of an objective can be assessed through ensuring defined conditions are met or carried out. Such conditions include:

prohibitions to undertake a specific action (for example, to achieve the objective 'Minimise impacts to soil', during construction of a pipeline the assessment criteria may be to prevent ripping or grading of the right-of-way in gibber plain areas).

requirements to carry out certain actions in accordance with approved procedures or industry accepted standards (for example, the design, construction, operation and maintenance of pipelines is in accordance with Santos procedures and Australian Standard AS 2885).

Goal Attainment Scaling (GAS) criteria – Environmental objectives requiring visual assessment are likely to be prone to uncertainties of subjective judgement. To minimise this, GAS is used to measure such objectives against a series of criteria described by a written description and/or photographically (refer Appendix B). GAS is applicable to measuring objectives related to minimising disturbances to natural vegetation and soil, and rehabilitation of right-of-way (ROW), borrow pits and access tracks. Goal Attainment Scaling (GAS) criteria are referenced where available (see Table 2-1) and presented in Appendix B.

Scientific studies/monitoring - In some cases, the assessment of the environmental objectives may not be possible in the shorter term and may require longer term monitoring and scientific evaluation. In such cases, assessment criteria may be in the form of longer term data and information gathering for example, the objective 'Avoid contamination of soil, groundwater and/or watercourses' may require a study to determine the potential impact of cumulative hydrocarbon leaks.

Each objective for the SACBJV production and processing operation (refer 2.1) will be assessed using a selection of the assessment options outlined above. This will enable the Operators and others to determine whether the objectives are being achieved. Comments on any variances will be recorded and reported where required (Section 3).



Table 2-1: Environmental Objectives and Assessment Criteria

Environmental Objectives

Comment Guide to How Objectives Can Be Achieved Assessment Criteria

Objective 1

Minimise the risk to public and other third parties.

The criteria for assessing the achievement of this objective have been developed on the basis of current understanding of the risks associated with production and processing operations.

The key to achieving this objective in relation to production and processing operations including pipelines and production facilities is to ensure that the visual prominence of these areas including access track(s) is minimised to the extent where it is difficult for third parties to detect and therefore access them. Also, in the case where a third party encounters a site, adequate needs to be displayed to hinder any third party interference with the infrastructure. Similarly, backfilling of excavations and removal of rubbish should be carried out.

Fires or explosions at facilities could result in complications resulting in a spill of production fluids (formation water and hydrocarbon), atmospheric emissions, disturbance of native vegetation and wildlife habitat and risk to employees, contractors and the public.

The movement of heavy equipment may present a risk to the safety of employees, contractors and third parties (i.e. tourists).

All employees and contractor personnel complete a safety induction prior to commencement of work in the field.

All employees and contractor personnel undertake a refresher induction every 2 years.

Signage in place to warn third parties of access restrictions to operational areas, with particular warnings when potentially dangerous operations are being undertaken.

Permit to work systems in place for staff and contractors in dangerous situations.

All appropriate PPE (personnel protective equipment) is issued and available as required in accordance with company operating requirements and applicable standards.

Effective Emergency Response Plan (ERP) and procedures are in place in the event of a fire or explosion.

Annual exercise of ERP.

Communication of rig moves and other potential hazards to safety associated with drilling and well operations to potentially affected parties prior to commencement of operations.

Reporting systems for recording injuries and accidents in place, and annual; (at minimum) review of records to determine injury trends. Implementation of appropriate corrective actions.

Ensuring safety management plans are updated and reviewed.

Reasonable measures implemented to ensure no injuries to the public or third parties.





Objective 2

Minimise disturbance and avoid contamination to soil.

The impacts associated with soil disturbance can potentially include wind and water erosion and dust generation. The main sources of disturbance to soils is associated with pipeline, road and facility construction, creation of borrow pits, restoration activities, vehicle movement in off-road locations and sub-surface excavations (i.e. trenching, sumps and borrow pits).

Construction Activities (eg. pipelines and roads)

Santos operational procedures and guidelines are in place and will be followed for construction activities, for example to conserve soils resources:

Consider alternate routes during planning phase to minimise environmental impacts

Works are restricted to construction ROW.

The need to traverse sensitive land systems and the method of managing the impacts will be justified in accordance with company procedures.

Annual audit of construction practices.

0, +1 or +2 GAS criteria are attained for goals related to this objective as listed in Appendix 2 to 5.

No unauthorised off-road driving or creation of shortcuts.

No construction activities are carried out on salt lakes, steep tableland land systems or wetlands land systems (as defined in EIR).

Potential sources of contamination are associated with pipeline leaks/spills, spills of fuel or chemicals stored on site and disposal of waste waters and produced formation waters. Disposal of hydrostatic test water is also a potential source of contamination during pipeline construction if water is treated with chemicals prior to use.

Fuel and Chemical Storage, Handling and Transportation

All fuel, oil and chemicals are stored, handled and transported in accordance with appropriate standards.

Fuel and chemical storage, handling and transport procedures are reviewed and monitored in audit process.

Records of spill events and corrective actions are maintained in accordance with company procedures.

Spills or leaks are immediately reported and clean up actions initiated.

Logged incidents are reviewed annually to determine areas that may require corrective action to reduce spill volumes in subsequent years (and drive continual improvement).

A study into development of a Soil Health Index (SHI) for impacted soils and sediments is currently being undertaken. This will ultimately assist in the rehabilitation of spill sites to a level consistent with appropriate adjacent land uses.

No spills/leaks outside of areas

designed to contain them.

Soils remediated to a level consistent with the SHI requirements. Also refer to Objective 12.





Objective 2 cont.


Spill Response / Contingency Planning

Results of emergency response procedures carried out in accord with Regulation 31 show that oil spill contingency plan in place in the event of a spill is adequate and any necessary remedial action needed to the plan is undertaken promptly.

Oil spill contingency plan (reviewed annually) is up to date with specific scenarios relating to spills to creeks and floodplain areas.

Spill response equipment is audited annually.

Annual spill response training exercise is undertaken.

Oil/Condensate Spills (Pipeline/Road Transport)

Pipelines are compliant with AS2885 pipeline standards

Pipeline Management System is reviewed annually.

Pipelines are inspected and maintained in accordance with Pipeline Management System



No spills/leaks outside of areas designed to contain them.

Level of hydrocarbon continually decreasing for in situ remediation of spills.

Soils remediated to a level as determined by the SHI process.

Produced Formation Water (PFW)

A study into development of a Soil Health Index (SHI) for impacted soils and sediments is currently being undertaken. This will ultimately assist in the rehabilitation of water disposal/evaporation ponds to a level consistent with appropriate adjacent land uses.

The study will also enable an assessment of contaminants of concern in PFW in order to determine disposal criteria.

0, +1 or +2 GAS criteria are attained for goals related to produced formation water impacts on soil, as listed in Appendix 2 (26-29), 5, 6 and 7

PFW contaminant levels are below disposal criteria.

PFW EMP developed and objectives achieved.





Objective 2 cont.


Waste Disposal (domestic, sewage and sludges)

Covered bins are provided for the collection and storage of wastes.

All loads of rubbish are covered during transport to the central waste facility.

Pits are not established in locations, which pose an unacceptable hazard to stock or wildlife.

All domestic wastes are disposed of in accordance with EPA licensing requirements.

0, +1 or +2 GAS criteria for ‘Waste material’ objective as listed in Appendix 2 (17-19), is attained.

No spills or leaks from sewage treatment process and sludge pits.

For LTU’s contamination confined to designated treatment area.

Objective 3

Avoid the introduction or spread of pest plants and animals and implement control measures as necessary.

Activity associated with pipeline, road and access track construction, such as movement of vehicles and equipment, is a potential source of weed or disease introduction and spread. The most effective technique to prevent the introduction and spreading of weed species is to ensure that vehicles and equipment are appropriately cleaned prior to entry construction activities.

Where appropriate, weed and feral animal management strategy are in place (avoidance and control strategies).

Vehicle and equipment wash downs will be initiated in accordance with the management strategy.

No weeds or feral animals are introduced to operational areas.





Objective 4

Minimise disturbance to drainage patterns and avoid contamination of surface waters and shallow groundwater resources.

The main threats to drainage patterns and surface waters, and shallow ground waters are considered to be interruption of natural flows as a result of earthworks. Construction activities in the Cooper Basin should aim to minimise any impact to existing drainage systems. This may be achieved by avoiding sensitive areas and utilizing appropriate construction methods to avoid windrows.

Construction Activities (eg. pipelines and roads)

Constructed activities undertaken are designed and managed to avoid diversion of water flows.

0, +1 or +2 GAS criteria are attained for goals related to this objective as listed in Appendix 2 to 5.

Construction activities (i.e. access tracks) are located and constructed to maintain pre-existing water flows (i.e. channel contours are maintained on floodplains and at creek crossings).

No water (surface or groundwater) contamination as a result of production activities.

There is potential for contamination from chemical and fuel storage areas, from oil and gas systems at well heads, during transportation of fuel and chemicals and during transportation of wastes. Localised contamination may result from spills or leaks of well operations chemicals (eg. corrosion inhibitors) during storage and handling.

Fuel and Chemical Storage, Handling and Transportation

All fuel, oil and chemicals are stored, handled and transported in accordance with appropriate standards.

Fuel and chemical storage, handling and transport procedures are reviewed and monitored in audit process.



Logged incidents are reviewed annually to determine areas that may require corrective action to reduce spill volumes in subsequent years (and drive continual improvement).

SHI project currently being undertaken will assist in the rehabilitation of spill sites to a level consistent with appropriate adjacent land uses.



No water (surface or groundwater) contamination as a result of production activities.





Objective 4 cont.

Minimise disturbance to drainage patterns and avoid contamination of surface waters and shallow ground water resources.

Spill Response / Contingency Planning

Results of emergency response procedures carried out in accord with Regulation 31 show that oil spill contingency plan in place in the event of a spill is adequate and any necessary remedial action needed to the plan is undertaken promptly.

Oil spill contingency plan (reviewed annually) is up to date with specific scenarios relating to spills to creeks and floodplain areas.

Spill response equipment is audited annually.

Annual spill response training exercise is undertaken.

The major threat of spills is the threat to soil, vegetation and watercourses directly impacted by the spill. Therefore, the achievement of this objective also consequently contributes to the achievement of objectives 3 and 6 in relation to minimising the impacts on natural vegetation and soil respectively.

As spills in the Cooper Basin will tend to be contained by the soil within the area of the spill, any wide ranging environmental threat is considered very unlikely. However, the focus of assessing this objective will primarily be on reducing the number of spills over time.

Avoidance of spills will be paramount in areas where the spill can be potentially spread beyond the immediate confines of the spill area into sensitive environments such as creeks and wetlands.

Oil/Condensate Spills (Pipeline/Road Transport)

Pipelines are compliant with AS2885 pipeline standards

Pipeline Management System is reviewed annually.

Pipelines are inspected and maintained in accordance with Pipeline Management System




Level of hydrocarbon continually decreasing for in situ remediation of spills.



A study into development of a Soil Health Index (SHI) for impacted soils and sediments is currently being undertaken. This will ultimately assist in the rehabilitation of water disposal/evaporation ponds to a level consistent with appropriate adjacent land uses.

The study will also enable an assessment of contaminants of concern in PFW in order to determine disposal criteria.

0, +1 or +2 GAS criteria are attained for goals related to produced formation water impacts on soil, as listed in Appendix 2 (26-29), 5 and 6.

PFW contaminant levels are below disposal criteria.






Review status of PFW facilities and develop an Environmental Management Plan (EMP) to achieve the objectives of the SA EPA Environment Protection (Water Quality) Policy, 2003, as appropriate.

PFW EMP developed and objectives achieved.

Objective 4 cont.

Minimise disturbance to drainage patterns and avoid contamination of surface waters and shallow ground water resources.

Waste Disposal (domestic, sewage and sludges)








Objective 5

Avoid disturbance to sites of known cultural and heritage significance.

The aim of the objective is to ensure that any sites of cultural (Aboriginal or Non-Aboriginal) heritage significance are identified and protected.

Consultation with stakeholders (i.e. government agencies, stakeholders etc) in relation to the possible existence of heritage sites, as necessary.

Heritage report forms completed for any sites or artefacts identified, and report forms forward to the Department of State Aboriginal Affairs (DOSAA).

Survey records are kept and are available for auditing.

Areas requiring remediation which lie outside previously surveyed sites should be surveyed in accordance with company heritage clearance procedures.

Note: Where a negotiated agreement or determination for heritage clearance is in place, compliance with the negotiated agreement or determination takes precedence over the above criteria.

Proposed construction sites and access tracks have been surveyed and any sites of Aboriginal and non-Aboriginal heritage identified.

Any identified cultural and heritage sites have been avoided.

0, +1 or +2 GAS criteria are attained for ‘Aboriginal Heritage’, as per Appendix 2 (30-31).





Objective 6

Minimise loss of aquifer pressures and avoid aquifer contamination.

This objective seeks to protect the water quality and water pressure of aquifers that may potentially be useful as water supplies, and to maintain pressure in target aquifer.

The Water Resources Act 1997 is administered by the Department of Water, Land and Biodiversity Conservation.

The volume/flow of water used by the Moomba Plant is continuously monitored to ensure appropriate management.

Water usage is continuously monitored, reviewed and management strategies implemented to minimise wastage.

Review water licensing requirements and allocation plans.

There is no uncontrolled flow to the surface (i.e. no free flowing bores).

Note: The Drilling and Well Operations

EIR and SEO provides detailed discussion on aquifer issues.

Objective 7:

Minimise disturbance to native vegetation and native fauna.

Primary risks to native fauna include clearing of habitat and obstruction of movement through cleared areas, the presence of borrow pits, fuel and chemical storage and management, and waste management activities.

Construction Activities

Proposed construction areas have been assessed for rare, vulnerable and endangered flora and fauna species before the commencement of construction.

Consider alternate routes during planning phase to minimise environmental impacts

Assessment records are kept and are available for auditing.

Any sites of rare, vulnerable and endangered flora and fauna have been identified, flagged and subsequently avoided.

0, +1 or +2 GAS criteria for ‘Minimise impacts on vegetation’ objective are attained as listed in Appendix 2 to 4 and 6 during site selection and construction.

Borrow Pits

Pits are not established in locations which pose an unacceptable hazard to stock or wildlife (i.e. not within 50m of any roads or access tracks, well leases or other plant and equipment).

Borrow pits are restored as soon as practicable after material extraction is complete to a standard consistent with the surrounding land use.

Borrow pits are restored to minimise water holding capacity, where agreements are not in place with stakeholder

In recognised conservation reserves (i.e. Innamincka Regional Reserve) excavations are left in a state as agreed with the responsible statutory body.

0, +1 or +2 GAS criteria for ‘Minimise impacts on vegetation’ objective, as listed in Appendix 4 are attained during site selection and construction.





Fuel and Chemical Storage and Management

Refer to assessment criteria for objectives 2 and 4.

Objective 7 cont:

Minimise disturbance to native vegetation and native fauna. Waste Management




PFW pits are fenced as appropriate to minimise wildlife access.

Refer to assessment criteria for objectives 2, 4 and 11.

Objective 8:

Minimise air pollution and greenhouse gas emissions.

Atmospheric emissions occur as a result of standard production and processing operations. Emissions of particular environmental significance are:

combustion by-products (eg. oxides of nitrogen, carbon monoxide and sulphur dioxide);

organic carbon and carbon particulates (black smoke); and

flared hydrocarbons (gases).

Conduct production operations in accordance with appropriate industry accepted standards.

Continually review and improve operations.

Appropriate emergency response procedures are in place for the case of a gas leak.

Gathering Systems/Satellite Facilities/Moomba Plant

Compliance with EPA requirements.

Objective 9:

Maintain and enhance partnerships with the Cooper Basin community.

The importance liaison with and contribution to the local community is recognised by the South Australian Cooper Basin Operators. Notification, consultation, contribution to community activities, projects and events and membership of relevant organisations are considered to be key strategies for ensuring partnerships with the local community are enhanced.

Relevant affected parties are notified and consulted on proposed activities.

Forward development plans are presented to the local community.

Local community projects and events are sponsored and supported where appropriate.

Industry membership of appropriate regional land management committees and boards i.e. the Lake Eyre Basin Consultative Council, Marree Soil Conservation Board, and Catchment Committees.

No unresolved reasonable

complaints from the community.





Objective 10:

Avoid or minimise disturbance to stakeholders and/or associated infrastructure.

Communication and the establishment of good relations with stakeholders and community are fundamental to Limiting disturbance as much as practicably possible. Many pastoral properties are certified under the Organic Beef or CattleCare accreditation schemes and therefore may be affected by fuel and chemical storage, moving machinery and contaminated sites.

Induction for all employees and contractors covers pastoral, conservation, legislation and infrastructure issues.

Relevant stakeholder are notified prior to survey and construction of well sites, camp sites and access tracks and undertaking of operations (pursuant to Petroleum Regulations). Borrow pits left open (unrestored) if requested by stakeholder and upon receipt of letter of transfer of responsibility to stakeholder.

Gates or cattle grids are installed to a standard, consistent with pastoral infrastructure in fences where crossings are required for access.

All gates left in the condition in which they were found (i.e. open/closed).

Potential sources of contamination are fenced as appropriate to prevent stock access.

System is in place for logging stakeholder complaints to ensure that issues are addressed as appropriate.

Requirements of the Cattle Care and Organic Beef accreditation programs are complied with.

In recognised conservation reserves (i.e. Innamincka Regional Reserve) excavations are left in a state as agreed with the responsible statutory body.

No unresolved reasonable stakeholder complaints.

Objective 11:

Optimise waste reduction and recovery.

Waste reduction requires continual improvements in purchasing, efficiency of use and reuse. Due to the distances involved, the costs of recycling a large range of products is not possible. However, continual review of recycling options is required to ensure that any opportunities are taken advantage of.

Chemical and oil is purchased in bulk. ‘Bulki bins’ or other storage tanks are in place for large volume items.

Fencing around waste disposal facility is regularly inspected and maintained.









Objective 12:

Remediate and rehabilitate operational areas to agreed standards.

Rehabilitation/ abandonment plans for surface activities will be developed in consultation with relevant stakeholders Construction Site and Access Track Restoration

Compacted soil areas have been ripped (except on gibber and tablelands) and soil profile and contours are reinstated following completion of operations.

No unresolved reasonable stakeholder complaints.

Contaminated Site Remediation

Contaminated sites are remediated in accordance with criteria developed with the principles of the National Environment Protection Measure for Contaminated sites and in consultation with the EPA.

Construction Site and Access Track Restoration

The attainment of 0, +1 or +2 GAS criteria for (refer Appendices 2&3):

- “minimise visual impact of abandoned well sites” - “minimise visual impact of abandoned access tracks” - “re-establish natural vegetation on abandoned well sites

and access tracks” Borrow Pit Restoration

The attainment of 0, +1 or +2 GAS criteria for (refer Appendix 5):

- “minimise impact on vegetation” - “minimise impact on soil” - “minimise visual impacts”

Objective 13:

Minimise as far as reasonably practicable interruptions to natural gas supply.

Adequate contingencies are in place which seek to address a prudent level of security of supply in the case of short and unforseen interruption events (eg. adequate gas storage).

Pipelines are designed, operated and maintained in accordance with AS 2885.

Plant and equipment are designed, operated and maintained in accordance with appropriate industry accepted standards.

Emergency Response Plan (ERP) and procedures are in place and exercised.

Results and recommendations of plant and facility hazard reviews, including the five (5) yearly Fitness for Purpose assessment, are appropriately addressed.

No interruptions to natural gas supply which caused significant social disruption



3 Reporting

Petroleum Regulation 12 (2) requires an SEO to identify events that could cause a serious incident or a reportable incident within the meaning of Section 85 of the Petroleum Act, 2000.

3.1 Serious Incidents

Section 85 of the Act defines a serious incident as an incident arising from activities conducted under a licence in which any of the following repercussions occur:

1. A person is seriously injured or killed.

2. An imminent risk to public health or safety arises.

3. Serious environmental damage occurs or an imminent risk of serious environmental damage arises.

4. Security of natural gas supply is prejudiced or an imminent risk of prejudice to security of natural gas supply arises.

5. Unauthorised encroachment by third party on pipeline easement that results in contact of the pipeline.

6. Any incident where it is reasonably likely to result, or has resulted, in one or more gas customers being informed that their gas supply is or is likely to be interrupted and an interruption of gas supply to the customer(s) could reasonably be expected to cause social disruption such as electricity supply cuts for periods of more than one day or gas supply restrictions to commercial and domestic customers

Pursuant to Regulation 12 (2), the incidents listed below are considered to be serious incidents that may arise from production and processing operations:

any spill of fuel, oil or hazardous material which encroaches onto land used for purposes other than petroleum production and processing or into groundwater supplies

any disturbance to sites of Aboriginal or non-Aboriginal heritage significance

explosion or fire at any facility or pipeline

pipeline failure that threatens gas supply or poses an imminent safety or environmental risk

an unplanned event likely to or results in potential interruption to gas supply and the interruption may cause significant disruption for more than one day or result in supply restrictions (refer Objective 13).



3.2 Reportable Incidents

Reportable incidents are incidents (other than a serious incident) arising from activities conducted under a license issued under the Petroleum Regulations 2000.

Pursuant to Regulation 12(2), the incidents listed below are considered to be reportable incidents that may arise from SACBJV operations:

any spill or leak of fuel/chemical outside areas designed to contain them

a complaint from a stakeholder as a result of operations (for example pipeline construction activities)

removal of rare, vulnerable or endangered flora and fauna species (without appropriate permits and approvals)

any introduction of weed species

detected unauthorised third party access to facilities

any incident which results in less than the prudent level of gas being supplied to a purchaser for more than 12 hours.



4 Consultation

A stakeholder consultation process was a key component of the preparation of the Environmental Impact Report for Production and Processing Operations (Santos Ltd 2003) and for this Statement of Environmental Objectives prior to its submission to PIRSA for review and approval. Consultation workshops were held in both Adelaide and Moomba and an overview of this process, including a list of key stakeholders, is provided in Appendix 7. Throughout the consultation process, a range of issues were raised resulting in changes to both the EIR and SEO. These comments and responses to them are summarised in Appendix D.

5 References & Further Reading

Malavazos, M. & Dobrzinski, I. 1995. Goal Attainment Scaling Applied to Assessing Environmental Impact of Petroleum Operations in the Cooper Basin, May, SA DME Report DME 16/90.

PIRSA, 1998. Field Guide for the Environmental Assessment of Abandoned Petroleum Well Sites in the Cooper Basin, South Australia, Prepared by the Petroleum Group, Dept of Primary Industries and Resources SA, April.

Santos 1999. Code of Environmental Practice, Production and Processing, September 1999.

Santos 2003. South Australian Cooper Basin Joint Venture, Environmental Impact Report: Production and Processing Operations.



Appendix 1:

Environmental Hazards and Potential Consequences for Production and Processing Operations



Environmental Hazards and Potential Consequences

The EIR identified potential environmental hazards and consequences associated with SACBJV production and processing operations in the South Australian sector of the Cooper Basin.

Summaries of the environmental hazards and potential consequences associated with various production and processing operations, as identified in the EIR, are provided in Tables A-1 to A-17, below. Environmental objectives outlined in this SEO have specifically been identified in response to the environmental hazards and potential consequences discussed in the EIR (Chapter 7 and 8, SACBJV 2003).

Gathering Systems

Table A-1: Summary of Environmental Hazards and Potential Consequences - Pipeline Construction

Hazard Potential Consequence/s

Movement of machinery and vehicles Dust generation Soil compaction Soil erosion Damage to native vegetation Injury or death of native fauna Disturbance to cultural heritage sites Introduction and/or spread of weeds Damage to third party infrastructure Disruption to land use (eg. grazing and recreation) Increased public access to remote areas

Spills and leaks associated with chemical and fuel storage

Contamination of soil, groundwater and/or watercourses Access to contaminants by stock and wildlife

Earthworks Injury or death of fauna in construction zone Loss of visual amenity Damage to native vegetation Introduction and/or spread of weeds Disturbance to natural drainage patterns Damage to third party infrastructure Soil erosion and siltation of watercourses Inversion of soil profile Dust generation Soil compaction Disturbance to cultural heritage sites

Ignition of fire along ROW Disturbance to cultural heritage sites Loss of vegetation and fauna habitat Release of particulate emissions to the atmosphere Disruption to land use (eg. grazing and recreation)

Disposal of hydrotest water Contamination of soil and/or watercourse Loss of vegetation and fauna habitat as a result of soil or water

contamination



Table A-2: Summary of Environmental Hazards and Potential Consequences - Pipeline Operation


Explosion or fire along an oil or gas pipeline

Contamination of soil and/or watercourse Atmospheric pollution Danger to health and safety of employees, contractors and

possibly the public Loss of vegetation and fauna habitat Disruption to land use (eg. grazing)

Spill or leak associated with pipeline failure

Contamination of soil and/or watercourse Disruption to land use (eg. grazing) Danger to health and safety of employees, contractors and

possibly the public Atmospheric pollution (gas) Access to contaminants by stock and wildlife

Spill or leak associated with nodal compressor failure

Contamination of soil and/or watercourse Disruption to land use (eg. grazing) Danger to health and safety of employees, contractors and

possibly the public Atmospheric pollution (gas) Access to contaminants by stock and wildlife

Spill associated with transport of oil and condensate (via truck)

Contamination of groundwater, surface water and soil Danger to health and safety of employees, contractors and

possibly the public Access to contaminants by stock and wildlife

Satellite Facilities

Table A-3: Summary of Environmental Hazards and Potential Consequences - Oil and Gas Satellite Operation


Explosion or fire at the satellite Danger to health and safety of employees, contractors and possibly the public

Contamination of soil and/or watercourse Atmospheric pollution (gas)

Flooding of surrounding floodplain/watercourses

Contamination of soil and/or groundwater Damage to infrastructure (eg. evaporation ponds) Access to contaminants by stock and wildlife

Spills and leaks associated with chemical and fuel storage

Contamination of soil, groundwater and/or watercourses Access to contaminants by stock and wildlife

Fugitive emissions of methane and organic carbon from the process plant

Release of greenhouse gases contributing to climatic warming

Venting of CO2, H2S, and CO Release of greenhouse gases contributing to climatic warming

Flaring of propane, butane, methane and ethane from process plants

Release of greenhouse gases contributing to climatic warming

Loss of containment of gas or oil (pipeline rupture or leaks from satellite equipment)

Contamination of soil and/or watercourse Atmospheric pollution Danger to health and safety of employees, contractors and

possibly the public Access to contaminants by stock and wildlife Loss of vegetation and fauna habitat



Table A-4: Summary of Environmental Hazards and Potential Consequences - Oil & Gas Satellite Utilities, Disposal of Domestic Waste & Sewage


Storage of waste at camps and transport and disposal to landfill (i.e. Moomba waste facility)

Scavenging by native and pest species Pest outbreaks Contamination of soil and/or groundwater

Spills or leaks associated with disposal and treatment of sewage in septic tanks

Localised contamination of soil and/or groundwater

Produced Formation Water

Table A-5: Summary of Environmental Hazards and Potential Consequences - Produced Formation Water (PFW) Disposal


Storage and disposal of PFW at satellites

Contamination of soil and/or groundwater Access to contaminants by stock and wildlife

Flooding of surrounding floodplain/watercourses

Contamination of soil and/or groundwater Damage to infrastructure (eg. evaporation ponds) Access to contaminants by stock and wildlife

Moomba Plant – Process Facilities

Table A-6: Summary of Environmental Hazards and Potential Consequences - Inlet Separation Process


Oil sludge disposal to sludge pit then to LTU

Contamination of soil and/or groundwater

PFW disposal to northern evaporation pond

Contamination of soil and/or groundwater Access to contaminants by stock and wildlife

Sour water disposal to sour water pit then Lake Brooks

Localised acidification of soil

Table A-7: Summary of Environmental Hazards and Potential Consequences - Raw Gas Conditioning Plant


Air Emissions (CO2 and H2S) Release of greenhouse gases contributing to climatic warming

Disposal of oily water to northern evaporation pond and Lake Brooks


Access to contaminants by stock and wildlife



Table A-8: Summary of Environmental Hazards and Potential Consequences - Liquids Recovery Process


Oil sludge disposal to sludge pit and LTU


Disposal of oily water to interceptor pit then northern evaporation pond


Access to contaminants by stock and wildlife

Table A-9: Summary of Environmental Hazards and Potential Consequences - Gas Supply (Interruption to Natural Gas Supply)


Explosion or fire at the plant Disruption to gas supply Danger to health and safety of employees, contractors and

possibly the public

Loss of containment of gas (pipeline rupture or leaks from plant equipment)

As above

Table A-10: Summary of Environmental Hazards and Potential Consequences - Liquids Processing


Spills or leaks associated with storage of oil and condensate (tank farm)

Contamination of soil and/or watercourse Danger to health and safety of employees, contractors and

possibly the public Access to contaminants by stock and wildlife Loss of vegetation and fauna habitat

Spills or leaks associated with chemical and fuel storage and use

As above.

Table A-11: Summary of Environmental Hazards and Potential Consequences - Diesel Storage and Refuelling


Leak or spill associated with storage and handling of diesel fuel

Contamination of soil and/or watercourse Danger to health and safety of employees, contractors and

possibly the public Access to contaminants by stock and wildlife

Loss of vegetation and fauna habitat



Moomba Plant - Utilities

Table A-12: Summary of Environmental Hazards and Potential Consequences - Water Treatment


Discharge of saline washdown water to Lake Brooks

Localised salinisation of soil as a direct result of process saline washdown water

Continual blow down of waste water to Lake Brooks

As above

Extraction of water from GAB Depletion of GAB and sub-artesian water supplies

Spills or leaks associated with failure of Gidgealpa to Moomba water pipeline

Localised acidification and/or salinisation of soil

Table A-13: Summary of Environmental Hazards and Potential Consequences - Steam Generation


Leaks and/or spills associated with chemical storage and handling

Danger to health and safety of employees and contractors

General Infrastructure

Table A-14: Summary of Environmental Hazards and Potential Consequences - Road Construction and Maintenance


Earthworks (eg. grading of ROW) Injury or death of fauna in construction zone Loss of visual amenity Damage to native vegetation Introduction and/or spread of weeds Disturbance to natural drainage patterns Damage to third party infrastructure Soil erosion and siltation of watercourses Dust generation Soil compaction Disturbance to cultural heritage sites

Movement of machinery and vehicles Dust generation Soil compaction Soil erosion Damage to native vegetation Injury or death of native fauna Disturbance to cultural heritage sites Introduction and/or spread of weeds Damage to third party infrastructure Disruption to land use (eg. grazing and recreation) Increased public access to remote areas

Spills and leaks associated with fuel and chemical storage and handling

Contamination of soil and/or watercourse Access to contaminants by stock and wildlife

Ignition of fire along ROW Disturbance to cultural heritage sites Loss of vegetation and fauna habitat Release of particulate emissions to the atmosphere Disruption to land use (eg. grazing and recreation)

Presence of borrow pits Injury to or loss of stock and wildlife Dispersal of watering points and redistribution of stock

movements

Movement of road construction material Introduction and/or spread of weeds



Table A-15: Summary of Environmental Hazards and Potential Consequences - Waste Disposal Facilities


Domestic waste disposal to Moomba waste facility

Scavenging by native and pest species Pest outbreaks Contamination of soil

Storage and disposal of contaminated soil to LTU

Localised contamination of soil and/or watercourses

Arsenic dump (disused) Localised contamination of soil and/or watercourses

Disposal of chemical waste to licensed disposal facility

Localised contamination of soil and/or watercourses

Disposal of asbestos to asbestos waste depot

Contamination of soil

Spills or leaks associated with sewage plant chemical storage and handling


Sewage sludge storage and disposal Localised contamination of soil and/or groundwater

Disposal of treated effluent to Lake Brooks

Increased nutrient levels in Lake Brooks

Table A-16: Summary of Environmental Hazards and Potential Consequences - Operation of Moomba Airport


Leaks and/or spills associated with chemical and fuel storage and handling


Presence of fauna in vicinity of airport Disruption or injury to fauna (i.e. birds)

Table A-17: Summary of Environmental Hazards and Potential Consequences - Fire Training Ground Activities


Fire or explosion Danger to health and safety of employees and contractors Atmospheric pollution

Spills or leaks associated with storage and disposal of oil




Appendix 2:

Criteria for Assessing Production and Processing Operations



EXPECTED

GOAL EXCEEDED

EXPECTED

GOAL ATTAINED

MINOR SHORTFALL

SIGNIFICANT SHORTFALL Ref. Goal

+2 +1 0 -1 -2

CONSTRUCTION ACTIVITIES 1 Minimise ROW

width standard (15m).

ROW never exceeds, and often is less than, 15m on the standard section (>25% of ROW).

ROW never exceeds and is sometimes less than 15m on the standard section (<25% of ROW).

ROW does not exceed 15m on the standard section.

ROW sometimes exceeds 15m on the of standard section (<25% of ROW).

ROW often exceeds 5m on the standard section (>25% of ROW).

2 Minimise ROW width - creek crossings (5m).

ROW width does not exceed 5m at creek crossings.

ROW width exceeds 5m at creek crossings.

ROW width exceeds 9m at creek crossings.

3 Minimise ROW width - dense vegetation (9m).

ROW width is generally less than 9m on the ‘dense vegetation’ sections.

ROW width is less than 9m on parts of the ‘dense vegetation’ sections, and never exceeds 9m.

ROW width does not exceed 9m on the ‘dense vegetation’ sections.

ROW width sometimes exceeds 9m on the ‘dense vegetation’ sections (<25% of ROW).

ROW width often exceeds 9m on the ‘dense vegetation’ sections (>25% of ROW).

4 Leave trees on ROW

No trees removed, only vegetation of priority 4 in handbook cleared. No trees or vegetation removed.

Trees and vegetation removed in area where could not have been avoided.

Vegetation of priority 2 or 3 in Field Guide removed in area where could have been avoided.

Trees of priority 1 in Field Guide1 removed in area where could have been avoided.

5. Trim (rather than clear) trees in dense woodland.

Extensive tree trimming in designated areas.

Minor tree trimming in designated areas. Some evidence of tree removal where trimming appropriate.

No trimming evident. Obvious evidence of tree removal where trimming appropriate.

6. Leave rootstock (ie. minimal grading of ROW).

No evidence of rootstock removal on ROW beyond 3m of trench line. ROW is either only lightly graded or not graded.

Evidence of some rootstock removal beyond 3m of trench line (<25% of ROW).

All rootstock removed. ROW generally deeply graded for full ROW width (>25% of ROW).

7. Stockpile topsoil. Topsoil removed to a depth of 50mm and stockpiled separately.

No evidence of topsoil having been stockpiled.

8. Remove all windrows.

No windrows associated with the pipeline are evident (except on dunes where some windrows are inevitable after reprofiling, but will quickly disappear).

Occasional windrows remain on the ROW (<10% of ROW).

Regular windrows remain on the ROW (>10% of ROW).

CONSTRUCTION ACTIVITIES (cont.) 9. Follow crown

protocol. No crown

present, or crown Crown over trench but

Backfill insufficient to fill

1 Field Guide refers to the Field Guide to the Common Plants of the Cooper Basin – South Australia and Queensland (SEA Pty Ltd)



EXPECTED GOAL

EXCEEDED

EXPECTED GOAL

ATTAINED MINOR

SHORTFALL SIGNIFICANT SHORTFALL Ref. Goal

+2 +1 0 -1 -2 present over the trench with periodic breaches.

periodic breaches (where required) not evident.

trench.

10. Avoid subsidence.

No subsidence evident on pipe trench.

Minor subsidence (<50mm) evident (<10% of the trench).

Significant subsidence (<50mm) evident, or regular minor subsidence (>10% of the trench).

11. Respread topsoil and cleared vegetation.

Where topsoil and vegetation removed, it has been respread over full width of ROW, excluding access track.

Topsoil and vegetation respread over the ROW, but some areas have been missed.

Little evidence of topsoil and vegetation respread over the ROW. Stockpiled topsoil and vegetation left unspread.

12. Reprofile dunes to pre-existing contours.

Dune profiles have been restored consistent with surrounding dune profiles for all dunes crossed.

Dune profiles have generally been restored consistent with surrounding dune profiles with occasional exceptions (<10% of dunes).

Dune profiles have not been restored consistent with surrounding dune profiles for numerous dunes crossed (>10% of dunes).

13. Reprofile creek banks to pre-existing contours.

Creek/channel banks restored to original profile.

Creek/channel banks not restored to original profile.

14. Rip compacted areas (eg. access tracks).

All compacted soil ripped.

Some areas of compacted soil have not been ripped (<25%).

Numerous areas of compacted soil have not been ripped (>25%).

15. Leave trench open <1 day to minimise fauna impacts.

Trench never open for >1 day.

Trench rarely open for >1 day (<20% of pipeline).

Trench occasionally open for >3 days (<20% of pipeline).

Trench often open for >4 days (>20% of pipeline).

CAMPSITES 16. Avoid clearance

of trees. No evidence that

trees have been cleared at the campsite.

Evidence that trees have been cleared at the campsite.

WASTE MATERIAL 17. Remove all

rubbish. No evidence of

waste on ROW or at campsites.

Evidence that rubbish has been cleaned up, but some rubbish still on ROW

Little or no evidence that rubbish has been cleaned up.

18. Recycle waste materials where appropriate.

All waste pits audited prior to backfill to ensure recyclable material not deposited. No recyclable waste present in pits.

Evidence/records show that recyclable material has been returned to Moomba Waste Management Depot.

No evidence/records that recyclable material has been returned to Moomba Waste Management Depot.

Open waste pits contain recyclable materials.

19. Disposal sewage appropriately.

Evidence/records show that appropriately designed sewage pits have been constructed.

No evidence/records of appropriately designed sewage pits.

Open pits of waste water and sewage. Pits are not of approved design.



EXPECTED GOAL

EXCEEDED

EXPECTED GOAL

ATTAINED MINOR

SHORTFALL SIGNIFICANT SHORTFALL Ref. Goal

+2 +1 0 -1 -2

AT INTERSECTION WITH PUBLIC TRACKS 20. Reduce ROW

width to less than 9m.

ROW width reduced to 5m at track crossing.

ROW width less than 9m at track crossing.

ROW width 9m at track crossing.

ROW width greater than 9m at track crossing.

ROW width greater than 15m at track crossing.

21 Dogleg ROW to break line-of-sight.

ROW cannot be identified, except by signposts (required by legislation).

ROW doglegs at track crossing so that less than 50m is visible either side of the track.

ROW doglegs at track crossing so that less than 100m is visible either side of the track.

ROW doglegs at track crossing, but 250m of ROW is visible either side of the track.

ROW does not bend at track crossing and greater than 250m of ROW is visible either side of the track.

22. Leave vegetation on ROW to conceal ROW

Some trees and/or shrubs have been left on the ROW to break the line of sight.

All vegetation has been cleared from the ROW

23. Re-establish the verge of the track.

Verge of track is intact.

Verge has not been re-established.

PASTORAL ISSUES 24. Repair fences to

‘as before’ standard.

Fences repaired to ‘as before’ standard.

Fences repaired, but slightly poorer than before (but still stockproof).

Fences either not repaired, or very poorly repaired (not stockproof).

25. Consult with stakeholder.

Stakeholder consulted, and happy with the Project.

Stakeholder consulted, but has some concerns.

Stakeholder not contacted concerning the Project.

FORMATION WATER (see also Produced Formation Water Field Inspection and Desk Audit GAS below) 26. No visible oil on

surface. No visible oil in

unlined ponds. Some visible oil in unlined ponds (covers <10% of the pond surface).

Significant amount of visible oil in unlined ponds covers >25% of pond surface.

27. Guidelines yet to be set based on PFW study

28. Fence formation water pond.

Formation water pond is fenced.

Formation water pond is not fenced.

29. Stakeholder is satisfied with arrangements.

Written evidence that stakeholder is satisfied with water disposal arrangements.

No written evidence that stakeholder is satisfied with water disposal arrangements.

Stakeholder provides written complaint as to state of water disposal arrangements.

ABORIGINAL HERITAGE 30. Sites identified in

DEF are not disturbed.

Sites identified by the archaeological survey are recorded, reported and remain undisturbed.

No evidence of disturbance to sites, but some procedural recommendations not followed.

There is evidence that sites identified by the archaeological survey have been disturbed. Key recommendation not followed.

31. Correct protocol followed for sites discovered during construction.

Either no sites encountered, or records show correct procedures were followed to avoid damage to additional sites.

Evidence that additional sites have been disturbed, and there are no records of ameliorative measures having been taken to avoid damage.



Appendix 3:

Criteria for Assessing Right-of-Way (ROW) Rehabilitation

EXPECTED GOAL

EXCEEDED

EXPECTED GOAL

ATTAINED

MINOR SHORTFALL

SIGNIFICANT SHORTFALL Ref. Goal

+2 +1 0 -1 -2 1. ROW is stable

(ie. no evidence of gullying or blowouts 2 years after ROW restoration).

No evidence of erosion on ROW

Minor rills and/or deflation on ROW, but unlikely to worsen (<200mm deep).

Significant gully or blowout on ROW (>200mm deep).

2. Good vegetation 2 years after ROW restoration.

Vegetation indistinguishable from surrounding landscape.

Vegetation type and density consistent with surrounding landscape, but less mature.

Some sections of the ROW have poor revegetation (<25% of ROW).

Revegetation of the ROW is generally poor (>25% of ROW).



Appendix 4:

Criteria for Assessing Borrow Pit

Construction and Rehabilitation

Construction Version 1: Aug 1997

Goals Minimise impacts on vegetation Protect unknown sites of natural, scientific, or heritage significance

Minimise visual impacts

Objectives Perennial vegetation clearance minimised

Avoid sites Site pit appropriately

-2 Trees of priority 1 in Field Guide1 removed in area where could have been avoided.

Sites disturbed. Borrow pit less than 20m from road.

-1 Trees of priority 2 or 3 in Field Guide removed in area where could have been avoided.

Borrow pit less than 50m from road.

0 Trees and vegetation removed in area where could not have been avoided.

Sites identified, flagged and avoided. Borrow pit more than 50m from road. Visible from road due to lack of screening vegetation.

+1 No trees removed, only vegetation of priority 4 in Field Guide cleared.

Borrow pit shielded from road by utilizing screening vegetation or landform.

+2 No trees or vegetation removed. Sites identified, flagged and avoided by 100m.

Borrow pit not visible from road.

Rehabilitation Version 1: Aug 1997

Goals Minimise impact on vegetation

Minimise impact on soil

Minimise visual impacts Site to be left in a clean and tidy

condition Objectives Acceptable revegetation

after rainfall Minimise erosion Borrow pit effectively recontoured

and ripped Rubbish removed

-2 No revegetation evident. Severe erosion evident.

No recontouring of pit has occurred – pit sides are very steep. Topsoil and vegetation not respread.

Large items of litter present.

-1 Revegetation localised on the base of the pit but none or very little on the sides of the pit.

Moderate erosion. Pit sides battered but not ripped. Small items of litter present on site.

0 Perennial grasses and shrubs revegetated, type consistent with surroundings. Some bare patches still present. Vegetation cover uniform over base and sides of pit.

Minor erosion along the sides of the pit.

Pit sides battered and ripped along the contour, but is still highly visible. Topsoil and vegetation respread over disturbed area.

No evidence of litter.

+1 Pit contours blend well into surrounding landscape, although still evident.

+2 Vegetation type and density indistinguishable from surrounding landscape.

No erosion anywhere on the pit.

Pit contours indistinguishable from surrounding landscape. Access ripped.




Appendix 5:

Criteria for Assessing Produced Formation Water Disposal

- Field Inspections Version 1: Dec 1996

Goals Minimise adverse impacts on soil, vegetation, native fauna and livestock Objectives Minimise oil discharge into environment Minimise salination of soil

-2 Oil visible on water in evaporation pond. Salination and seepage evident outside designated pond area, such as adjacent dune corridor.

-1 Oil visible on water in holding ponds but not in evaporation pond.

No salination evident outside designated area. However more than 75% of the unflooded soil area in the designated area has evidence of salination.

0 Oil visible in interceptor pits but not in any holding and evaporation pond(s).

Salination only evident within designated area.

+1 No oil visible in either the evaporation, holding or interceptor ponds, only some stains on the banks of the interceptor pit.

+2 No oil visible in either the evaporation, holding or interceptor ponds.

No salination evident anywhere.



Appendix 6: Criteria for Assessing Produced Formation Water (PFW) Disposal - Desk Audit

Version 2: July 1999 Goals Minimise impact on

vegetation Protect known sites of

natural, scientific or heritage significance

Minimise impact on native fauna and

livestock

Minimise adverse impacts on soil

Minimise impact on ground water

Minimise impact on surface water

Objectives Perennial vegetation clearance minimised

Vegetation impact by water

inundation minimised

Consult relevant groups

and survey sites

Water quality acceptable for native fauna consumption

Water quality tolerable for

livestock consumption

Minimise oil and grease

discharge

Minimise concentration

of contaminants in soil

Minimise salt and organic

concentrations in groundwater

Prevent discharge into natural water

bodies -2 Trees of

priority 1 in Field Guide1

removed in area where could have been avoided.

Local vegetation dead.

Relevant group(s) antagonised as a result of site interference.

Oil and grease concentration greater than 30ppm.

TDS and organics concentration above limit for original use of aquifer water.

Unlicensed discharged of water to a creek, river or lake.

-1 Vegetation of priority 2 or 3 in Field Guide removed in area where could have been avoided.

Local vegetation dying.

No consultation or field surveys carried out.

Oil and grease concentration greater than 30ppm.

TDS and organics concentration in aquifer equal to limit for original use of aquifer water.

Interceptor pit located in area prone to inundation by flooding

0 Trees and vegetation removed in area where could not have been avoided.

No observed change to local vegetation.

Consultation with relevant groups, and field surveys carried out.

Oil and grease concentration less than 30ppm.

Guidelines are yet to be set based on the PFW Studies

TDS and organics concentration in aquifer less than limit for original use of aquifer water.

Water disposal ponds located in areas which are only inundated during floods. No interceptor pits located in area prone to inundation by flooding

+1 No trees removed, only vegetation of priority 4 in handbook cleared.

Guidelines are yet to be set based on the PFW studies

Oil and grease concentration less than 30ppm.

+2 As above. No observed impacts to local vegetation.

Agreement of stakeholders on site usage and protection obtained.

No contaminants in water.

No contaminants in water.

Oil and grease concentration zero.

No soil contaminants present.

TDS and organics concentration in aquifer unchanged.

Water disposal facility located above 100-year flood level.




Appendix 7:

Criteria for Assessing Oil Spill Remediation/Rehabilitation Version 2: July 1999

DESK AUDIT CRITERIA (12 months after spill) FIELD AUDIT CRITERIA Goals Minimise THP1

concentration in soil Minimise

concentration of other contaminants2

in soil

Minimise TPH concentration in

surface and groundwater

Minimise concentration of

other contaminants in surface and groundwater

Minimise impacts on vegetation (5 years

after spill)

Minimise soil contamination (12 months after spill)

Response speed to minimise hazard (48

hours after spill detected)

Weighting 15% 15% 15% 15% 15% 10% 15% +2 TPH concentration

zero or equal to background levels.

Concentration of other contaminants in soil zero or equal to background levels.

TPH concentration zero or equal to background levels.

Concentration of other contaminants zero or equal to background levels.

Vegetation type, density and maturity indistinguishable from surrounding landscape.

No evidence of soil discolorisation or hydrocarbon odour in soil.

Area restored to original state.

+1 Vegetation type and density the same as surrounding landscape, but less mature.

Very faint soil discolorisation evident, and no hydrocarbon odour in soil.

Site recontoured with earthworks evident, no free oil or evidence of spill.

0 Vegetation re-established, but some bare patches still evident.

Faint evidence of soil discolorisation and slight hydrocarbon odour in the soil.

Free oil removed. Spill staining still evident and hydrocarbon odour only slightly detectable.

-1 Very little revegetation; site mostly bare compared to surrounding landscape.

Areas of significant staining and very strong hydrocarbon odour in the soil.

Hydrocarbon fumes very strong and overpowering.

-2

Guidelines are yet to be set based on the PFW and SHI Studies.

No revegetation evident.

More than 50% of the spill site has significant soil discoloration and a strong hydrocarbon odour in the soil.

Free oil visible.

Notes: 1 TPH: Total Petroleum Hydrocarbon 2 Other contaminants: ie. other than TPHs 3 SHI: Soil Health Index (SHI) Studies are currently being undertaken to provide remediation criteria for soils and sediments.



Appendix 8

Overview Of Stakeholder Consultation Process



APPENDIX 9 STAKEHOLDER COMMENTS AND RESPONSES



Stakeholder Comment Santos Response / Comment General • Avoid using the word ‘avoid’ Appropriate in some cases.

• Reference to ‘avoid’ and ‘minimise’ Wording has been altered to ensure consistency.

• Objectives should include restoration of affected areas. Included appropriate remedial actions in Objective 12. Additional objective has been

added.

• Define timeframes for assessment criteria and management strategies (i.e. what is regular).

• Criteria for objective are often statements and not specific procedures or actions.

Assessment criteria have been refined in response to this comment.

• Additional objective is required to address protecting ‘key sites’ and broaden to include ‘visual amenity’.

Key sites are considered to be covered under objectives which require the protection of heritage sites, water resources, habitats etc. It was considered that the addition of an additional specific objective would be repetitive. Similarly visual amenity is a key assessment criterion for a number of the objectives, particularly for Objective 12.

• “Strict” and “guidelines” are mutually exclusive. Reference to strict has been removed.

• Need to define procedures. • Santos procedures should be followed (as an operational

experience in reducing impacts).

Santos specific procedures are not defined as these cannot be imposed on all Operators. All operators, including Santos, must ensure that procedures are developed as part of their management systems to ensure that all objectives are met.

• Improve awareness and education. Criteria defined to ensure annual induction. Objective 1: Continuously improve the safety of employees, contractors, the public, and other third parties. • Why is objective just soil and not ‘soil and water’. Water (surface and groundwater) is covered under Objective 4. • Roads and access tracks Some roads are the responsibility of Transport SA and not just Santos. Transport SA

must also have appropriate procedures and design standards. • Include ‘appropriate mitigation and remedial actions’ or words

to this effect as well as ‘minimise’. Objective 12 has been added to cover mitigating actions and remediation for each environmental element (soil, water and native vegetation etc).

• There are no criteria to assess public safety associated with vehicle and equipment moves.

Criteria added. Management strategies are identified in the EIR (Appendix G)



Stakeholder Comment Santos Response / Comment Objective 2: Conserve soil resources by minimising disturbance and avoiding contamination. • Why does this not include water? Water included in Objective 4. • Need to have no unauthorised tracks (off road driving). This is covered in staff and contractor inductions. Management strategies and

assessment criteria are in place to assess performance.

Objective 3: Avoid the introduction and spread of pest plants and animals and implement control measures as necessary. • Include feral animals. Objective wording has been altered to cover this. • ‘All vehicles…’ – dedicated wash down areas Vehicle washdown is undertaken on an ‘as required’ basis. • Catchment committees are trying to have washdown bays

installed. This is noted.

• Known weed infestations should be identified and managed accordingly.

This is not only a management strategy defined in the EIR, but also depending upon the weed species, a legislative requirement.

• Rig moves considered high risk (particularly from Queensland). This is recognised (refer EIR Appendix G). • Cats are also an issue. This is recognised (EIR Section 8.2.16). Objective 4: Reduce disturbance to drainage patterns and avoid contamination of surface waters and shallow groundwater resources. • Interference of blockage of natural drainage patterns is avoided. Already covered in the SEO. • Add surface waters. Added into objective wording above.

Objective 5: Avoid disturbance to sites of known cultural and heritage significance. Improve cultural heritage awareness. Education and induction programs aim to achieve this awareness.

Objective 6: Minimise loss of aquifer pressures and avoid aquifer contamination. Use ‘Avoid’ contamination of aquifers. Objective wording has been changed. Add ‘significant’ before contamination. Significant not added as difficult to define. Change objective to include aquifers that are currently used or

may be potentially used. Overall objective is to avoid changes to aquifers (non-oil and gas bearing formations), whether it be pressure or water quality. The model identifies aquifer salinity which is a defining criteria and it is not considered necessary to complicate the objective to include just the protection of used or potentially used zones.



Stakeholder Comment Santos Response / Comment Objective 7: Conserve natural environment habitats by minimising disturbance to native vegetation and reducing risks to native fauna. Don’t knock down trees. Current procedures avoid large shrubs and trees unless absolutely necessary.

Booklets are provided to ensure that flora with a high conservation significance are avoided (refer to assessment criteria in Appendix B).

Objective 8: Minimise air pollution and greenhouse gas emissions. Make less smoke. Monitoring of emissions and operations undertaken in accordance with standard

industry practice. Any issues that are identified as part of monitoring programs are addressed in accordance with principles of ecologically sustainable development.

Objective 9: Maintain and enhance partnerships with the Cooper Basin community. Contribution to the management of threatening processes. Petroleum companies contribute to managing threatening processes in the

community, such as weeds and feral animal control. Contributions also to local natural resource management committee programs (i.e. the Marree Soil Conservation Board and Catchment Committees).

Objective 10: Avoid or minimise disturbance to livestock, pastoral infrastructure and landholders. Should include “livestock” in the above objective. Objective amended. Should be criteria for the impact of helicopters on livestock. Not considered that establishment of a measurable objective is possible. The use of

the helicopter is minimised where possible due to cost, and low flying is also minimised due to safety concerns.

Objective 11: Optimise waste reduction and recovery.

No specific comments recorded.

Objective 12: Remediate and rehabilitate operational areas to agreed standards.

No specific comments recorded.

statement of environmental objectives: production and...

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