Document Number: QCOPS-OPS-ENV-PCE-000028 Document Title: Common Systems EOP HSSE MANAGEMENT PROCEDURE ENVIRONMENTAL OPERATING PROCEDURE FOR COMMON SYSTEMS Scope and application This procedure is developed as part of QGC’s Environmental Management System (EMS) that meets the international standard AS / NZS ISO 14001. In accordance with the EMS and Section 4.4.6 of AS / NZS ISO 14001, key operations and activities associated with significant environmental aspects must be controlled to: ▪ Avoid, minimise and manage environmental risk; ▪ Comply with legal and other requirements; and ▪ Continually improve. This procedure applies to all aspects of operation, maintenance and repairs relating to Common Systems’ infrastructure (Common Systems Assets, as referred in Appendix D), following handover to the operational team. This procedure, therefore, does not consider environmental management associated with: ▪ the construction and/or commissioning of Common Systems infrastructure; ▪ the operational management of regulated and unregulated storage structures; ▪ the Condamine Power Station (CPS); ▪ the Water Treatment Plants (Northern and Central) Unless otherwise specified, the Operations Manager, Common Systems is accountable for implementing this procedure.
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
Document Number: QCOPS-OPS-ENV-PCE-000028
Document Title: Common Systems EOP
HSSE MANAGEMENT PROCEDURE
ENVIRONMENTAL OPERATING PROCEDURE FOR COMMON SYSTEMS
Scope and application This procedure is developed as part of QGC’s Environmental Management System (EMS) that meets the international standard AS / NZS ISO 14001. In accordance with the EMS and Section 4.4.6 of AS / NZS ISO 14001, key operations and activities associated with significant environmental aspects must be controlled to:
▪ Avoid, minimise and manage environmental risk;
▪ Comply with legal and other requirements; and
▪ Continually improve.
This procedure applies to all aspects of operation, maintenance and repairs relating to Common Systems’ infrastructure (Common Systems Assets, as referred in Appendix D), following handover to the operational team.
This procedure, therefore, does not consider environmental management associated with:
▪ the construction and/or commissioning of Common Systems infrastructure;
▪ the operational management of regulated and unregulated storage structures;
▪ the Condamine Power Station (CPS);
▪ the Water Treatment Plants (Northern and Central)
Unless otherwise specified, the Operations Manager, Common Systems is accountable for implementing this procedure.
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
9.0 Records ......................................................................................................................................... 43
Appendix A Definitions ..................................................................................................................................... 44
Appendix B Acronyms/Abbreviations .............................................................................................................. 46
Appendix C Key References/Associated Documents ....................................................................................... 48
Appendix D Common Systems Assets (in-scope) ............................................................................................. 49
Appendix E Federal Approvals and Environmental Authorities Conditions Assessment ................................ 55
Appendix F SQP Declaration ............................................................................................................................ 64
Appendix G DAWE Approval Letter .................................................................................................................. 65
1.1 Purpose and Scope This Environmental Operating Procedure (EOP) addresses the environmental management and reporting requirements for operation of QGC’s Common Systems infrastructure.
Under the Petroleum and Gas (Production and Safety) Act 2004, a holder of a pipeline licence must comply with Australian Standard 2885.3 which requires that an operations environmental management plan be developed and implemented. In complying with this EOP and environmental approvals requirements, the holder will be carrying out the petroleum activities in a way that manages the risk of environmental harm to as low as reasonably practicable (ALARP).
Additionally, in accordance with conditions 3 and 29 of the EPBC Approval 2008/4399, an Environmental Management Plan for PPL 153, 154 and 155 must be prepared and approved by the Department of Environment and Energy (DoEE).
This EOP supports the operation of QGC’s Common Systems infrastructure, outlining the environmental management measures to adhere to legislative and environmental approvals requirements and mitigate the environmental risks to achieve Shell’s goal of zero harm to people and the environment. This procedure covers the operational activities of managing Common Systems infrastructure and includes the establishment of environmental performance criteria, management measures, monitoring, auditing and corrective action requirements to protect the environment by managing risks to ALARP.
In scope of this EOP is the management of:
• Gas and water transmission pipelines (HDPE and steel) and all associated above ground infrastructure i.e., air release valves (ARV), high point vents (HPV), and low point drains (LPD).
• Receipt stations, delivery stations, main line valve (MLV) stations.
• Sales stations.
• Water pump stations.
• Telecommunication lines/towers associated with transmission pipelines.
• Outdoor high voltage oil filled power transformers and bunded transformer enclosures with associated oil/water separator.
• Indoor high voltage SF6 gas insulated switchgear.
• High voltage outdoor substations with SF6 gas insulated switchgear, oil filled power transformers and bunded transformer enclosures with associated oil/water separator.
• High voltage overhead powerlines and associated easement.
Activities and assets outside of the scope of this EOP and managed by other procedures comprise:
• Construction-related activities;
• Regulated and unregulated storage structures;
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
QCOPS-OPS-ENV-PCE-000028 Review due: Jun 2023
Responsible: Field Environment Advisor
Accountable: Operations Manager Common Systems RESTRICTED Revision: 07
• Monitoring infrastructure associated with seepage and groundwater bores;
• Condamine Power Station;
• Water treatment plants (Northern and Central);
• Monitoring associated with this procedure.
1.2 Document Revisions and Approval This document has been prepared by the Field Environment Advisor and shall be reviewed and endorsed in accordance with the RACIE Matrix at the front of this document. This document bears a revision status identifier which will change with each revision.
1.3 Distribution and Intended Audience This document is intended for use by Upstream Common Systems Operational teams, Upstream Common Systems Contractors, QGC Environment team, QGC Compliance team and all other QGC stakeholders. The document will be made available on the QGC intranet and document control system (eBentley).
In addition, this document must be submitted for review and approval of the DoEE and published on QGC’s website within 20 business days following approval.
2.0 References
2.1 Legislation, Approvals and Procedures This EOP along with subsidiary management plans and procedures must adhere to all applicable environmental approvals, legislation and standards. Environmental and planning approvals and legislation are outlined below with a comprehensive list of legislation, standards and referenced documents provided at Appendix B.
▪ Environmental Protection Act 1994;
▪ Nature Conservation Act 1992;
▪ Vegetation Management Act 1999;
▪ Environment Protection and Biodiversity Conservation Act 1999;
▪ Australian Standard 2885.3;
▪ ISO14001 International Standard Environmental Management Systems requirements for guidance;
▪ Shell HSSE & SP Control Framework;
▪ Shell Australia HSSE Incident Reporting Investigation and Follow up Procedure;
▪ All relevant Environmental Authorities; and
▪ EPBC 2008/4399- Federal Pipeline Approval applicable to PPL 153, 154 and155- conditions 3 and 29.
This document supersedes the following Environmental Management Plans:
▪ Environmental Management Plan - QCLNG Export Pipeline from Miles to MLV7- QCLNG-BG00-ENV-PLN-000003, Rev 4;
▪ Draft Environmental Management Plan Part A Export Pipeline (Narrows Crossing – Terrestrial Section)- QCLNG-BG03-ENV-PLN-000003. Rev A; and
▪ Environmental Management Plan Part B - Export Pipeline (Narrows Crossing- Marine Section)-Environmental Authority Application- QCLNG-BG03-ENV-PLN-000004, Rev B.
2.2 Environmental Management System (EMS) QGC operates an ISO14001-certified Environmental Management System as outlined in QGC HSSE & SP Management System Manual (QCQGC-BX00-HSS-MAN-000005). This EOP is the primary operational control document for implementing the EMS within QGC’s Common Systems infrastructure. EMS documents, as listed in Appendix C, support this EOP and can be accessed in eBentley.
3.0 Resources The following resources are required to implement this EOP.
3.1 Responsibilities The following responsibilities apply when undertaking activities covered by this document.
Table 1 – Roles and Responsibilities
Role Responsibilities
Operations Manager Common Systems
▪ Overall accountability for Common Systems infrastructure as detailed in thisEOP, including monitoring and maintenance;
▪ Provide adequate resources to ensure this procedure is adhered to;
▪ Ensure this procedure is followed in relation to management of CommonSystems infrastructure in their control;
▪ Ensure all personnel complete relevant environmental training
▪ Ensure the environmental performance criteria are met in accordance withthis procedure;
▪ Ensure Asset/Safety Critical Elements are reviewed and raised forcompletion;
▪ Ensure all environmental incidents are notified to the Field EnvironmentAdvisor (FEA) as soon as practicable (within 4 hours) to enable appropriatereporting to the regulator (where required);
▪ Ensure any incidents are appropriately reported in FIM;
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
▪ Ensure completion of incident investigations and identification and close out of any corrective and preventative actions;
▪ Provide input into applicable environmental forums to help drive environmental performance;
▪ Ensure Management of Change process is followed and engages FEA to consider environmental impacts;
▪ Drive a culture of compliance.
Water and Power Operations Manager
▪ Ensure this procedure is followed in relation to management of Common Systems infrastructure in their control;
▪ Ensure all personnel complete relevant environmental training to meet these requirements;
▪ Ensure the environmental performance criteria are met in accordance with this procedure.
Field Environment Advisor (FEA) for Operations
▪ Co-ordinate the communication of the requirements of this procedure to relevant personnel; including providing suitable environmental awareness training programs to ensure personnel are aware and understand the requirements of this procedure;
▪ Communication of potentially regulator-notifiable incidents to the Environment Upstream Lead;
▪ Assure the implementation of this procedure by Operations and provide feedback on quality of assurance as required;
▪ Assist with incident investigations, non-compliances and corrective and preventative actions;
▪ Provide environmental input into MOCs;
▪ Provide advice on environmental issues and drive a culture of environmental performance and improvement;
▪ Where required, engage QGC subject matter experts to ascertain technical environmental guidance;
▪ Provide assurance of operation inspection programs required for evaluation of compliance with this EOP;
▪ Support annual internal audit program.
Environment Compliance Lead and Environment Compliance Advisors
▪ Ensure Common Systems processes align to EMS requirements;
▪ Ensure this procedure is incorporated into the EMS internal audit program;
▪ Notify environmental incidents to the regulator, as required;
▪ Coordinate all communication with the Regulators;
▪ Prepare the relevant associated environmental annual returns and submit to the Regulators;
▪ Ensure regular review of the evaluation of compliance with this EOP and the annual audit program.
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
Lead Tenures/Permits ▪ Accountable for administering financial assurance calculations and submissions to administering authority relevant to associated environmental pipeline authorities;
▪ Permit applications, amendments and relinquishment relevant to the operation of transmission assets.
Lead Rehabilitation ▪ Technical environmental advice regarding, maintenance, decommissioning and rehabilitation; or escalation to subject matter experts if required;
Contractor ▪ Adhere to all relevant requirements of this procedure;
▪ Ensure suitable environmental training programs are implemented.
Access / Social Performance ▪ Respond to stakeholder communications relevant to this activity.
Transmission / HV Operators
All Staff (employees and
contractors)
▪ Complete necessary surveillance and maintenance tasks to reduce the risk of environmental impacts
▪ Raise any environmental concerns, promote best practices, and drive continual improvement;
▪ Follow procedures as required to ensure the environmental impacts of their work are minimised;
▪ Participate in the HSSE induction and any additional training programs;
▪ Seek advice and direction from the Field Environment Advisor about environmental requirements and issues; and
▪ Report environmental incidents and participate in incident investigations.
APA ▪ Owner of pipelines PPL 153, 154 and 155. Holder of the EA EPPG 945113. Refer to specific commercial contract for further details.
3.2 Finance
Common Systems Budget
The Environment Operations Manager or delegate must provide input into the budget as part of the annual business planning process to ensure all costs related to environmental elements, approvals, conditions and commitments are incorporated. This includes:
▪ Statutory fees and charges (annual returns); ▪ Offset programs and obligations under State and federal provisions (indirect offsets); ▪ Financial contribution to monitoring programs; ▪ Environmental management including equipment, incident investigation and clean up.
4.0 Risk Management QGC maintains Hazard and Effect Registers (HERS) which capture hazards and their respective controls associated with the Export Pipeline (E05), Gas Collection Header (GCH) and associated pipeline facilities (QCOPS-BX00-HSS-REG-000005) as well as field compression stations, central processing plants and gas and
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
water trunklines (QCOPS-BX00- HSS-REG-000004). The significant environmental risks have been extracted from the HERS and are provided below. The controls and recovery measures have been identified and are to be established such that the risks are managed to ALARP. The Shell Risk Assessment Matrix (RAM) is attached as Appendix E.
Below are the most significant risks that have been identified for Upstream Common Systems infrastructure.
Table 2 – Hazards and Effects- Common Systems
Environmental Attribute
Source(s) of Hazard
Threat Consequence (Potential) RAM Rating *
Controls
P A C E
Reinstatement and Rehabilitation / Water quality
Pipeline Construction or Maintenance
Lack of or inappropriate reinstatement or rehabilitation
Ineffective stormwater control
Lack of stabilisation / vegetation cover, erosion and sediment release off right of way and into watercourse or marine environment leading to contamination of water, habitat alteration, breach of EA conditions, habitat alteration, landholder complaints
Landholder complaints
Regulatory enforcement
0D 0D
2E 3D
- Civil design (erosion sediment control - berms, rocks checks, coir logs). - Depth of cover. - Mobile data system - Civil maintenance tracking. - Regular operator inspections including watercourse crossings.
Air Pipeline operations
Venting, seal failure, erosion/ corrosion
Release of hydrocarbon gas to the atmosphere, visible smoke, reputation impacts
0D 0D
2D 2D
- Emergency response plan. - Landowner liaisons. - Management Plans/Procedures i.e. Greenhouse Gas and Energy Management Plan Flare and Process Vent Management Plan and Leak Management Plan.
Biosecurity Areas outside of QGS tenements, properties within QGC’s tenements.
Import of contaminated machinery, vehicles or equipment to QGC worksites / private properties
Introduction or spread of invasive biosecurity matters, i.e. Weeds / pathogens / fire ants. Breach of legislation- Habitat alteration / impact Economic impact Landholder impacts / grievances
- Stakeholder Management; -Alternative arrangement agreement with impacted receptors
Waste Waste left on site
Incorrect disposal of regulated waste
Ineffective waste management.
Breach of EA Landholder complaint Increased disposal costs Reputational Damage Environmental Release
0D
0D
0D 2C
- Waste Manual; - Permit to Work system; -Offsite waste disposal treatment.
5.0 Performance Criteria Performance criteria have been established to benchmark environmental performance and compliance requirements for each key aspect in line with the risks outlined in section 4.0. Performance criteria ranked and recognised as a significant environment risk are highlighted in the following sections. The associated controls are managed through the referenced management system.
Soil and Groundwater
Activities that could cause disturbance to land and soil on QGC sites include:
• Loss of, degradation or contamination of topsoil and subsoil; and
• Impact on agricultural cropping land and soil productivity.
Objectives:
• To minimise soil loss and degradation; and
• To minimise impact to agricultural cropping land, soil productivity and increase rehabilitation and agricultural potential through appropriate land management practices.
Table 3 – Soil and Groundwater Management Performance Criteria
Number Performance Criteria Management System Responsible Person
SW01 All soil is managed in accordance with the site-specific soil management recommendations specified within the ATW while meeting the supporting requirements from the Soil Manual.
SW03 No instances of erosion and sediment mobilisation to waters or sensitive receiving environments (refer to Environmental Protection Act 1994 for ‘waters’ definition).
SW05 Civil maintenance works undertaken within water crossings have approved erosion and sediment control plans implemented compliant with both the Soil Manual and IECA 2008.
SW10 Contaminated land resulting from petroleum activities is remediated or encapsulated in a manner which is Suitably Qualified Person (SQP) certified and will not cause environmental harm.
Number Performance Criteria Management Document/ System
Responsible Person
NM01 Noise emissions from QGC activities to comply with noise limits listed in the relevant Environmental Authority at all nearby sensitive receptors (with exception where an alternative arrangement is in place for that activity)
Noise Manual
EAs
All staff
NM02 No recorded complaints relating to noise emissions from QGC activities
Noise Manual All staff
Air Quality and Visual Amenity
Activities that could cause air quality impacts include:
• Dust from vehicle and machinery movements; and
• Venting, seal failure, erosion/corrosion; and
• Release of air borne contaminants from machinery or activities.
Impacts:
• Air pollution / increased greenhouse gas emissions; and
• Harm to health of humans, flora and fauna.
Objectives:
• All operations will be consistent with the Qld Environmental Protection (Air) Policy 2008;
• Consultation with potentially affected sensitive receptors in accordance with the LAARs procedure; and
• Minimised air quality related complaints received from residents and landholders.
Table 6 – Air Quality Performance Criteria
Number Performance Criteria Management Document/System
Responsible Person
AQ01 Manage emissions of greenhouse gases in
accordance with the QGC Upstream
Greenhouse Gas and Energy Management
Plan (GHGEMP)
GHGEMP Operations Manager Common
Systems
AQ02 No environmental nuisance from the
release of noxious or offensive airborne
contaminants, dust or particulate matter at
any sensitive or commercial place.
Environmental
Protection (Air)
Policy 2008
Transmission/HV/Automation
& Telecom Superintendent /
Supervisor / Operator / Lead
Comms Engineer
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
RH04 Data is provided to GIS in a timely manner, particularly relating to Asset Lifecycle Stages as per QCLNG-OPS-ENV-PCE-000006 Spatial Data Model and Data Capture Dictionary, and the Contract (if applicable)
Number Performance Criteria Management Document/System
Responsible Person
RH06 Civil maintenance of rehabilitated areas is undertaken within timeframes from QCOPS-OPS-ENV-PCE-000026 Non-Conformance, Corrective Action and Preventative Action Procedure
RH07 Final Rehabilitation Acceptance Criteria measured against the highest ecological value adjacent land use or the pre-disturbed land use:
a) Greater than or equal to 70% of native ground cover species richness
b) Greater than or equal to the total per cent ground cover
c) Less than or equal to the per cent species richness of declared plant pest species
d) Where the adjacent land use contains, or the pre-clearing land use contained, one or more regional ecosystems, then at least one regional ecosystem from the same broad vegetation group, and with the equivalent biodiversity status or a biodiversity status with a higher conservation value as any of the regional ecosystems in either the adjacent land or pre-disturbed land, must be present.
Number Performance Criteria Management Document/System
Responsible Person
a) Greater than or equal to
70% of native groundcover
species richness;
b) Greater than or equal to the
total per cent ground cover;
c) Less than or equal to the per
cent species richness of
declared plant pest species;
d) Greater than or equal to
50% of organic litter;
e) Greater than or equal to
50% of total density of
coarse woody material; and
f) All predominant species in
the ecologically dominant
layer, that define the pre-
disturbance regional
ecosystem are present
RH09 Where there is a dam that is being or intended to be utilised by the landholder or overlapping tenure holder, the dam must be decommissioned to no longer accept inflow from the petroleum activity and the contained water must be of a quality suitable for the intended on-going uses by the landholder or overlapping tenure holder
Evaluation of Environmental
Compliance Procedure
Lead EMS, Compliance
and Reporting Advisor
Compliance and
Reporting Advisor
RH10 Records that demonstrate compliance with conditions within the ATW & Scope/Control Plan, including dates are submitted into contractually agreed database
Number Performance Criteria Management Document/System
Responsible Person
RH11 Erosion and sediment controls designed , installed and maintained as per IECA 2008.
Soil Manual Operations Manager
Common Systems
Transmission Superintendent/
Transmission Supervisor
RH12 Records that demonstrate compliance with the Reinstatement and Rehabilitation Manual and this Procedure.
Reinstatement and
Rehabilitation Manual
AS 2885.3/2012
Australian Pipelines and Gas
Association Ltd (APGA) Code of
Environmental Practice for
Onshore Pipelines
Operations Manager
Common Systems
Transmission Superintendent/
Transmission Supervisor
RH13 Asset maintenance, suspension and decommissioning shall be undertaken in accordance with approvals, legislation, codes of practice and industry standards
Reinstatement and
Rehabilitation Manual
AS 2885.3/2012
AS 2566/1998
AS 2601/2001
AS 3000/2018
AS 2067/2016
Australian Pipelines and Gas
Association Ltd (APGA) Code of
Environmental Practice for
Onshore Pipelines
Code of Practice – Upstream
Polyethylene Gathering
Networks – CSG Industry
Code of Practice – Demolition
work (Safe Work Australia)
Operations Manager
Common Systems
Transmission Superintendent/
Hazardous Materials
Common Systems shall ensure that all hazardous materials are contained and stored in a controlled and safe manner in accordance with relevant Legislation, Australian Standards and QGC procedures
Impacts:
• Land and surface water contamination; and
• Fire/explosion.
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
• To protect personnel, the public and the environment from harm due to transport, storage or use of chemicals;
• Compliance with license requirements for chemical and fuel storage; and Minimise incidents or spills resulting in surface or groundwater contamination.
Number Performance Criteria Management Document/System
Responsible Person
Transmission / HV
Supervisor/ Lead Comms
Engineer
Waste
Common Systems will ensure that all waste streams are identified and appropriately segregated on all worksites. The appropriate waste facilities will be installed and maintained throughout all Common Systems infrastructure.
Impacts:
• Land and water contamination;
• Health impacts to wildlife from consumption of waste; and
• Visual amenity
Objectives:
• Avoid and reduce waste at the source;
• Maximize reuse and recycling opportunities;
• Segregate waste at the source;
• Store and dispose of waste in accordance with regulatory requirements;
• Minimise contamination of soil, air or water as a result of inappropriate waste management; and
• Minimise impacts to the health of personnel or sensitive receptors.
Table 12 - Waste Management Performance Criteria
Number Performance Criteria Management Document/System
Under the Environmental Protection Act 1994, everyone has a duty to notify actual or potential environmental harm. In the event of an environmental incident:
• Implement immediate controls, if safe to do so (e.g. stop the leak, contain the spill);
• Notify Environmental Superintendent immediately
• Input the entry in to Fountain Incident Management (FIM); and
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
• Assist with incident investigation, development and close out of corrective and preventative actions and organize clean up (e.g. removal of contaminated soil).
The Environment Operations Manager shall determine if the incident requires reporting to the regulator e.g. DES and is responsible for regulator notification which is required within 24 hours of the incident occurring.
Environmental incidents that need to be reported may include, but are not limited to:
• Contamination of land, surface water or groundwater;
• Fauna injury or fatality;
• Inappropriate waste disposal;
• Introduction or spread of weeds and pests;
• Spills of production/associated water, chemicals, fuel, waste or other material;
• Unauthorized vegetation clearing; and
• Non-compliance with Environmental Authority conditions.
The Process for incident notification is as follows:
1. Relevant personnel refers incident to Environment Upstream Lead who determines if incident is notified to Environment Operations Manager; and
2. Environment Operation Manager and Compliance Team shall determine if the incident is a reportable incident under the relevant Environmental Authority.
All environmental regulator correspondence must be through Environmental Compliance team.
Table 13 – Incident Reporting and Notification Management Performance Criteria
Number Performance Criteria Management Document/System
Responsible Person
IR01 All notifiable incidents or the release
of any contaminants where
environmental harm has been caused
or may be threatened not in
accordance with the environmental
authority shall be reported in
accordance with the requirements as
listed in conditions of EA and/or
Federal Approval.
Shell Australia HSSE Incident
Investigation & Reporting
Procedure
Lead EMS, Compliance
and Reporting Advisor
IR02 All environmental incidents are
reported and recorded and
investigated as appropriate to the
QGC FEA/Environment Upstream
Lead.
Shell HSSE Incident Reporting,
Investigation and Follow up
Procedure
QGC EMS Non-conformance,
corrective action and
preventative action procedure
OICC
All staff
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
FIM Transmission / HV / Automation & Telecom Superintendent/
Transmission / HV
Supervisor/ Lead Comms
Engineer
Field Environment
Advisor
Contractor
IR05 Common Systems shall follow
contingency plans and emergency
procedures to deal with foreseeable
risks and hazards to prevent and
mitigate environmental harm.
Common Systems team to
follow Operational Hubs
Emergency Response Plan.
All Staff
IR06 All non-compliances with federal
approval conditions shall be notified
to Administering Authority within 5
business days.
Shell Australia HSSE Incident
Investigation & Reporting
Procedure
QGC EMS Non-conformance,
corrective action and
preventative action procedure
Lead EMS, Compliance
and Reporting Advisor
6.0 Implementation
6.1 Land Access Before works can commence on a landholders’ property, crews must obtain access approval via the Land Access Activity Request (LAAR) process. The LAAR process ensures that QGC meets its requirements under the P&G Act and any subsequent Land Access Rules agreed with the Landholder. LAARs application can require up to 10 business days to process however generally require at least four business days depending on the type of access required. For this reason, it is important to make LAARs requests as soon as practicable to ensure works are not delayed. Once LAARs are approved, strict Land Access Rules apply and must be adhered to by all personnel entering the property and so it is critical that these rules are understood and followed.
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
6.2 Upstream Delivery Process (UDP) and Access to Work (ATW) All civil works (e.g., infrastructure construction, laydowns, drain or basin upgrades, vegetation clearing) must be approved through the Upstream Delivery Process and receive a series of functional endorsements culminating in the key Access to Work (ATW) approval. The ATW will state all the environmental conditions to be satisfied for any scope of works undertaken. A copy of the ATW will be provided to the relevant stakeholders prior to the commencement of the works.
6.3 Communication and Awareness This procedure will be communicated to all Common Systems personnel via:
• Flash notifications;
• Specific tool box presentations made available for contractors and operations personnel to deliver; and
• Contract amendments, if required.
6.4 Environmental Induction and Training All personnel whether employees or contractors on site must have completed the QGC HSSE induction which presents a summary of QGC’s operations, HSSE requirements and expectation for operational behaviours as well as the Land Access training which covers (but not limited to) individual responsibilities when accessing land, individual obligations under the Land Access Code, QGC’s Golden Rules and Land Access Activity Requests (LAAR) permits including the Land Access Rules.
All personnel in Pipelines Operations team will undertake training on this procedure delivered by the Operations Field Environment Advisor. As a refresher, relevant sections of this EOP will be delivered as a toolbox and will be a part of the Safety Sunday presentations throughout the year.
Further environmental training and awareness include, but is not limited to:
• Toolbox talks and environmental awareness training;
• Environment Management System Awareness Module, available at Shell Open University (SOU); and
• QGC Environment Discipline Competence.
Training records are retained in accordance with the EMS Environmental Operational Control and Documentation Procedure (QCOPS-OPS-ENV-PCE-000020).
For further information, refer to HSSE Management Procedure- QGC HSSE Induction Procedure (QCQGC-BX00-HSS-PCE-000055) and EMS Competency, Training and Awareness Procedure (QCOPS-OPS-ENV-PCE-000024).
6.5 Complaints Management Complaints may be received from landowners and other stakeholders regarding environmental issues. For complaints received by general QGC staff & contractors, the following process is to be followed:
• Explain to the complainant that QGC has a process for managing complaints and request that the stakeholder forward their complaint on to the Community Feedback Line (1800 030 443 or [email protected]), to enable the complaint to be investigated.
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
• If possible, the receiver should also attempt to gather the following information:
o Name of complainant;
o Contact details (phone number/email address); and
o Nature of the complaint.
• Following the conversation with the complainant, the above information must be forwarded on to the Community Feedback Line or the relationship owner (if known) within 24 hours.
All valid complaints shall be appropriately investigated. For further information, refer to the Guideline for Complaints Handling (QCQGC-BX00-SPG-GDL-000001).
6.6 Ignition Source Management The mitigation of ignition of fire risk is embedded in QGC’s HSSE & SP Management System. Operational controls are included in the Hot Work Procedures (QCOPS-BX00-HSS-PCE-000008) and Attachment B “Hot Works” (“Model Contract Library HSSE”).
The HSSE & SP MS primary objective is the protection of life, asset and the environment.
The hierarchy of controls to be applied includes:
• Carry out hot work (any work that creates an ignition source, e.g., welding, burning, gas cutting, grinding and brazing) in area free of flammable materials;
• Eliminate ignition sources by selecting alternative work methods or equipment; and
• Implement controls to avoid the existence of flammable materials and ignition sources during hot work.
Fire Risk Management for MNES are included in Significant Species Management Plans listed below. In summary, QGC focuses on measures to manage ignition sources, and maintaining assets not required for ongoing operations to as close as practicable to background conditions and therefore prevent any risk as a result of petroleum activities. Operational assets are managed in accordance with legislative and code of practice requirements.
• Gas Collection Header, Export (QCLNG-BG00-ENV-RPT-000002);
• Narrows (QCLNG-BG03-ENV-PLN-000036);
• QCLNG Gas Fields (QCLNG-BX00-ENV-PLN-000025); and
• Surat Basin Acreage (QCQGC-BX00-ENV-PLN-000010)
6.7 Emergency Response
The following documents describe the process for responding to emergencies within Common Systems assets.
• QCLNG Pipeline Facilities Operational Safety Case- Control of Major Hazards (QCOPS-BG00-HSS-SAC-000001).
6.8 Management of Change QGC’s MOC process ensures all significant changes to Common Systems operations are appropriately examined, risk assessed, authorised and documented prior to implementation. The MOC process includes the assessment of environmental risks to ensure environmental compliance.
For further information, refer to Management of Change Procedure (QCOPS-BX00-HSS-PCE-000012).
7.0 Performance Evaluation
7.1 Environmental Audits Auditing forms an important part of ensuring compliance with legislation and continuous improvement of environmental procedures and performance.
The QGC HSSE Manager shall develop, in consultation with the relevant stakeholders, a schedule of internal audits. Common Systems infrastructure shall also be subject to external audits and inspections conducted by, or on behalf of, the Federal and State Administering Authorities, as required under QGC’s ISO14001 certification (annually), Environmental Authorities (generally 3 yearly) and Federal Approvals (generally 5 yearly).
For further information, refer to the EMS Internal Audit Procedure (QCQGC-OPS-ENV-PCE-0000013).
7.2 Environmental Monitoring All environmental monitoring is conducted in accordance with the EMS Environmental Monitoring Procedure (QCOPS-ENV-PCE-000021). Site specific requirements are documented in the relevant Environmental Work Instruction.
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
7.4 Environmental Action Tracking, Non-Conformances and Continuous Improvement
Tracking the progress of actions is critical for ensuring their close-out but also the overall improvement of operation standards. Actions may be a result of environmental issues or non-conformances identified during inspections, audits, incident investigations or raised by any personnel. All non-conformances identified shall be documented in a relevant manner (i.e. MDS, email, OICC, reports) and communicated to/discussed with the relevant area owner. Timeframes for actions to close non-conformity are based on the specific risk of the non-conformity as discussed with relevant area owner, Table 15 summarises general target timeframes.
Table 15 – General target timeframe to close non-conformity
9.0 Records Records of environmental operational control must be retained in accordance with the HSSE Records Management Standard. All environmental management plans and associated documents are managed via a document control system eBentley (Eb) . The current version of the document must be sourced from the document control centre.
For further information please refer to Environmental Operational Control and Documentation Procedure (QCOPS-OPS-ENV-PCE-000020).
Asset Lifecycle Aligns with business processes through planning, survey, design, review, issue for construction, as built, etc Refer to Spatial Data Model and Data Capture Dictionary
AS/NZS ISO 14001 The international standard for Environmental Management Systems.
Biosecurity Biosecurity is a set of measures designed to protect our operations and neighbouring
lands from the entry and spread of pest plants, animals and diseases
Dangerous Goods Dangerous goods are defined under the Australian Dangerous Goods Code and are
subject to additional legislative requirements for storage, use, transport and
disposal.
Disturbance Total area cleared to construct an asset.
Environmental Aspect An element of an organisation’s activities, products or services that can interact with
the environment, often known as the hazard. In other words, an aspect may be
thought of as an input or source of risk of an activity e.g. the aspect of storing
chemicals has the potential for spillage of chemicals to surrounding land and waters.
Environmental Harm Any adverse effect, or potential adverse effect (whether temporary or permanent
and of whatever magnitude, duration or frequency) on an environmental value, and
includes environmental nuisance, as defined in Environmental Protection Act 1994
(Queensland) Section 14.
Environmental Impact Any change to the environment, whether adverse or beneficial, wholly or partially
resulting from an organisation’s aspects.
Environmental
Management System
An organisation’s internal system for handling environmental issues. It establishes a
framework for tracking, evaluating and communicating environmental performance
and helps ensure that environmental impacts are identified, minimised and
managed.
Environmental Nuisance Any adverse effect or potential adverse effect on an amenity of an area that
interferes with the enjoyment of the area by persons, or any unsightly or offensive
condition caused by pollution as defined in Environmental Protection Act 1994.
Environmental Operational
Control
Operational controls are the various ways by which an organisation can ensure
activities are carried out to minimise environmental impact. Controls may take the
form of engineering and technology, preventative maintenance and procedures.
Hazard A source, situation, or act with a potential for harm to people, damage to assets or
impact on the environment or reputation.
Hazardous Materials An umbrella term used to describe any substance that, because of its chemical,
physical or biological properties, can cause harm to people, property or the
environment. It is a term that collectively describes substances which are classified
according to the hazard they present, including but not limited to ‘dangerous goods’,
‘combustible liquids’, and ‘hazardous substances’.
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
Pest Any organism, usually an animal, judged as a threat to humans. Most pests either
compete with humans for natural resources or transmit disease to humans, their
crops, or their livestock.
Rectification Civil maintenance works to ensure asset continues to meet performance criteria
Regulated Waste Regulated wastes are non-domestic waste listed in Schedule 7 of the Environmental
Protection Regulation 2008 (Queensland). They have additional legislative
requirements.
Rehabilitation Area of disturbance of asset no longer needed for ongoing petroleum activities that will not be redisturbed. During operations phase, these areas will be focussed on MNES, ESA and EVNT disturbance. If needed, civil works or other actions to stabilise site and promote towards final acceptance criteria.
Reinstatement Stabilisation by replacing topsoil and revegetating an operational asset or asset which will be required for future works or may need to be redisturbed (e.g. laydown, borrow pit, stockpile)
Safety Data Sheet (SDS) The internationally standardized way to document the hazardous properties of
chemicals and other hazardous agents. Chemical companies provide them to users
with appropriate safety and environmental information.
Sensitive Receptor An area or place (dwelling, building, public area or work place) where nuisance
impacts (noise, vibration, dust, and odour) could occur.
Significant Environmental
Aspect
Environmental aspect with a risk assessment value in a range having been defined as
‘significant’ due to high environmental damage, regulatory non-compliance and/or
stakeholder concerns.
Suitable Qualified Person
(SQP)
Person who has professional qualifications, training, skills or experience relevant to nominated subject matters and can give authoritative assessment, advice and analysis about performance relevant to the subject matter using the relevant protocols, standards, methods or literature.
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
Appendix E Federal Approvals and Environmental Authorities Conditions Assessment
Federal Environmental Approval EPBC 2008/4399
Relevant Condition EOP section Applicable Supportive Documentation under QGC’s EMS
3. The Environmental Management Plan (excluding the Narrows) must include:
a) provisions for detailed pre-clearance surveys by a suitably qualified ecologist along the entire length of the ROW, in accordance with conditions 5 to 10
a) Not applicable. Activities completed - pre-clearance surveys were conducted by an approved ecologist and have been published on QGC website.
b) measures to minimise native and riparian vegetation clearance and to minimise the impact on listed species, their habitat and ecological communities in accordance with management plans required for MNES under this approval;
b) Not applicable. Activities Completed – clearing activities have been finalised. Impact of clearing were managed in accordance with the, SSMP and Construction Management Plans.
c) measures to manage the impact of clearing on each listed species and ecological community in accordance with management plans required for MNES under this approval;
c) Not applicable. Activities Completed – clearing activities have been finalised. Impact of clearing were managed in accordance with the SSMP and Construction Management Plans.
d) measures to regenerate vegetation on the ROW where natural regeneration is not successful to a condition at least equivalent to the ROW condition prior to commencement;
d) Ongoing- Section 5.1.7- The EOP sets out the reinstatement performance criteria (for areas required for on-going petroleum activities) and rehabilitation performance criteria (for areas no longer required for on-going petroleum
Reinstatement and Rehabilitation Manual QCQGC-BX00-ENV-MAN-000005
approved by DoEE 9 January 2020
available https://www.shell.com.au/about-us/projects-and-
Relevant Condition EOP section Applicable Supportive Documentation under QGC’s EMS
activities) and assigns management responsibilities. Non-conformance with performance criteria are managed as per section 7.4 where a site specific action plan is required. Further details regarding Reinstatement and Rehabilitation specific non-conformity is contained within Reinstatement and Rehabilitation Manual sections 4.5 and 6.4.
e) measures to minimise impacts on fauna during pipeline construction, including
i. measures to protect MNES in the areas of the ROW where trenching is being undertaken, including measures to exclude listed terrestrial fauna from gaining access to those areas of the ROW where trenching is being undertaken;
ii. mechanisms to allow fauna to escape from the pipeline trench;
iii. daily morning surveys for trapped fauna;
iv. mechanisms for a suitably qualified person to relocate fauna; and
v. record keeping for all survey, removal and relocation activities.
e) Not applicable. Activities completed. Construction activities have been finalised. Impact of clearing were managed in accordance with SSMP and Construction Management Plans.
f) machinery wash down procedures and ongoing monitoring to minimise the spread and establishment of weeds in the ROW. Monitoring of weed infestations within disturbed areas must occur at least monthly during construction and then quarterly for a period of two years after
f) Ongoing-section 5.1.5. The EOP sets out biosecurity objectives and performance criteria and assigns management responsibilities..
Biosecurity Manual QCQGC-BX00-ENV-MAN-000002 Approved by DoEE May 2018, available:
Relevant Condition EOP section Applicable Supportive Documentation under QGC’s EMS
completion of construction. Appropriate weed control measures must be implemented. After the two-year period, the frequency of monitoring must be reconsidered by the proponent, based on the success of control measures, the level of infestations and pipeline maintenance activities
Biosecurity Procedure QCQGC-BX00-ENV-PCE-000010.
g) measures to manage and control feral animals that may spread due to the establishment of the ROW;
g) Ongoing-section 5.1.5. The EOP sets out biosecurity objectives and performance criteria and assigns management responsibilities..
Biosecurity Manual QCQGC-BX00-ENV-MAN-000002 Approved by DoEE May 2018, available:
h) measures for the management of ignition sources during construction, maintenance and decommissioning of the pipeline to protect habitat values from wild fire;
h) Ongoing- sections 6.6 and 6.7- EOP summarises QGC’s ignition source control applicable to its assets and emergency response.
Hot Work Procedures;
Attachment B “Hot Works” (“Model Contract Library HSSE”);
Upstream Operations Emergency Management Plan;
Environmental Response to Emergencies, Incidents and Gas Leaks Reporting; and
QCLNG Pipeline Facilities Operational Safety Case- Control of Major Hazards.
i) measures for the management of acid sulphate soils;
i) Ongoing- section 5.1.1 (performance criteria SW09). EOP includes the performance criteria for management of sulphate soils and assigns management responsibilities.
Soil Management Manual QCQGC-BX00-ENV-MAN-000004
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
Relevant Condition EOP section Applicable Supportive Documentation under QGC’s EMS
29.
The proponent must prepare an Environmental Management Plan for the crossing of the Narrows. This must include: a) if the crossing is undertaken concurrently with
the construction of one or more additional gas transmission pipelines (a 'bundled crossing'):
Part (a) is applicable (“bundled crossing”).
Construction of the pipeline is completed.
i. the roles and responsibilities of each party involved in the bundled crossing;
i) construction completed. Each one of the holders of the approval is responsible for operation and maintenance of the pipeline. Section 3.1 provides current responsibilities for the operations of the pipelines.
ii) details of the final pipeline route, engineering design and construction methodology, including details of the total number of gas transmission pipes including any pipelines for water supply and/or sewerage;
ii) Not applicable- activity completed - construction is finalised and as built drawings are available upon request. Spatial data has been updated into QGC’s GIS and is reported annually to the Department of Environment and Science under State Environmental Authority Annual Returns..
iii. potential impacts from the construction of the pipeline on listed threatened species, ecological communities, migratory species and World and
iii) Not Applicable-Construction is finalised. Refer to SSMPs, Dredge Management Plan and environment construction plans.
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
Relevant Condition EOP section Applicable Supportive Documentation under QGC’s EMS
National Heritage-listed values of the Great Barrier Reef;.
iv. mitigation measures to reduce impacts on listed threatened species, ecological communities, migratory species and World and National Heritage-listed values of the Great Barrier Reef;
iv) Ongoing- sections 5.1.6 and 5.1.7 present QGC’s objectives for biodiversity management and rehabilitation, including the performance criteria and assign management responsibilities.
Pipeline Significant Species Management Plan (SSMP) (QCLNG-BG00-ENV-RPT-000002)
Approved by SEWPAC 30 August 2013
available https://www.shell.com.au/about-us/projects-and-locations/qgc/environment/environment-management/management-plans.html;
Significant Species Management Plan (SSMP) Narrows Crossing (QCLNG-BG03-ENV-PLN-000036)
Approved by DoEE 19 October 2011
available https://www.shell.com.au/about-us/projects-and-locations/qgc/environment/environment-management/management-plans.html;
Reinstatement and Reinstatement Manual QCQGC-BX00-ENV-MAN-000005
approved by DoEE 9 January 2020
available https://www.shell.com.au/about-us/projects-and-locations/qgc/environment/environment-management/management-plans.html;
QCLNG Whole of Project Migratory Shorebird Management Plan
Approved by DoEE 26 July 2013
available https://www.shell.com.au/about-us/projects-and-
Environmental Management Plan Water Mouse (Xeromys myoides)
Approved by DoEE 26 July 2013
available https://www.shell.com.au/about-us/projects-and-locations/qgc/environment/environment-management/management-plans.html
v. proposed offset measures to compensate for unavoidable impacts on listed threatened species and ecological communities, listed migratory species and values of the World and National Heritage-listed Great Barrier Reef;
v) Ongoing- Section 3.2.1 EOP lists responsibility for applicable obligations and plans for the management of the offset areas. These commitments are contained within other documents approved by DoEE.
Monte Christo Offset Proposal prepared for all LNG proponents;
Approved by DoEE 27 September 2013
available https://www.shell.com.au/about-us/projects-and-locations/qgc/environment/environment-management/management-plans.html
Valkyrie Offset Area Management Plan (QCLNG-BX00-ENV-RPT-000117);
Approved by DoEE 30 April 2019
available https://www.shell.com.au/about-us/projects-and-locations/qgc/environment/environment-management/management-plans.html
Translocation and Management Plan for Cycas Megacarpa (QCLNG-E05-ENV-PLN-000001);
Relevant Condition EOP section Applicable Supportive Documentation under QGC’s EMS
Approved by DoEE 19 August 2016
available https://www.shell.com.au/about-us/projects-and-locations/qgc/environment/environment-management/management-plans.html
Bellalie Offset plan and offset area management plan (QCQGC-BX00-ENV-PLN-000020) Philotheca sporadica’s habitat offset;
Approved by DoEE 30 April 2019
available https://www.shell.com.au/about-us/projects-and-locations/qgc/environment/environment-management/management-plans.html
Charlie Trunkline Offset Delivery Plan and DES notification of agreement.
vi. measures for the management of acidsulfate soils (both potential and actual);
vi) Ongoing- section 5.1.1 (performance criteria SW09). EOP includes the performance criteria for management of sulphate soils and assigns management responsibilities.
Soil Management Manual QCQGC-BX00-ENV-MAN-000004
vii. measures for ongoing maintenance anddecommissioning of the pipelines.
vii) Maintenance of the pipeline isincluded in various sections as this is intrinsic to operations activities.
Section 5.1.7 of the EOP objectives and (performance criteria RH13) lists decommissioning strategy.
Reinstatement and Reinstatement Manual QCQGC-BX00-ENV-MAN-000005
approved by DoEE 9 January 2020
available https://www.shell.com.au/about-us/projects-and-locations/qgc/environment/environment-management/management-plans.html;
Relevant Condition EOP section Applicable Supportive Documentation under QGC’s EMS
Reinstatement and Rehabilitation and Procedure QCQGC-BX00-ENV-PCE-000011,
Environmental Authority EA EPPG00945113 (PPL153, 154, 155)
Relevant Condition EOP section Applicable Supportive Documentation under QGC’s EMS
(A13) An Environmental Management Plan (EM Plan) must be implemented that provides for the effective management of the actual and potential impacts resulting from the carrying out of the petroleum activities and which demonstrates compliance with the conditions of this environmental authority. Documentation relating to the EM Plan must be kept
All
(A14) The EM Plan required by condition (A13) must address, at least, the following:
(a) describe each of the following:
i) each relevant resource authority for the environmental authority
Section 1.1
ii) all relevant petroleum activities Appendix D
iii) the land on which the activities are to be carried out;
Appendix D
HSSE Management Procedure Issue date: Jun 2020
Environmental Operating Procedure for Common Systems
QCOPS-OPS-ENV-PCE-000028 Review due: Jun 2023
Responsible: Field Environment Advisor
Accountable: Operations Manager Common Systems RESTRICTED Revision: 07