PROJECT SEA DRAGON PTY LTD CORE BREEDING CENTRE AND ...

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PART C - ENVIRONMENTAL MANAGEMENT

PROJECT SEA DRAGON PTY LTD

CORE BREEDING CENTRE AND BROODSTOCK

MATURATION CENTRE, BYNOE HARBOUR

ENVIRONMENTAL IMPACT STATEMENT

Error! No text of specified style in document. part c - Environmental Management 2-i

Project Sea Dragon

Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour

Draft Environmental Impact Statement

PART C ‐ ENVIRONMENTAL MANAGEMENT 15‐284

15 ENVIRONMENTAL MANAGEMENT

15.1 TERMS OF REFERENCE ADDRESSED IN THIS CHAPTER

This chapter describes the environmental management measure proposed to minimise potential impacts

identified in the risk assessment and environmental assessment process.

Specifically, in relation to the potential impacts on the marine environment from construction of the project

and the discharge of water from the project, in the SoR the NT EPA state the following:

Generally, it is expected that benthic habitats would recover once the pipes are in place

The NT EPA is satisfied that the potential impacts and risks associated with installation of the seawater

intake pipe are unlikely to be significant and can be adequately managed through the implementation of

measures proposed in the NOI. In relation to the release point, there is potential for acid sulfate soils to be

disturbed in a limited area but impacts are likely to be localised and minimal if such material is managed

appropriately

The NT EPA considers that the interim water quality guidelines / values provide a reasonable basis for

assessment of potential impacts until the guidelines values can be refined

The NT EPA considers the proposed release of discharge water to Wheatley Creek is not likely to

significantly affect the regional water quality of Bynoe Harbour in the long term, though there may be

some localised, longer term enrichment near the point of discharge in Wheatley Creek.

Furthermore, in relation to erosion and sediment control, ASS, biting insects and weeds, the NT EPA state in the

SoR that potential risk associated with erosion and sediment control, acid sulfate soils, biting insects and weeds

can be adequately managed through the implementation of standard measures. Further adding, that the

proponent has committed to preparing and implementing detailed management plans for potential impacts of

the Project (Appendix 19).

Table 15‐1 summarises the requirements from the ToR for the Project of relevance to socio‐economics and

references where they have been addressed.

TABLE 15‐1 TERMS OF REFERENCE

Terms of Reference Sections

5 Environmental Management

The specific safeguards and controls proposed to be employed to minimise or

remedy environmental impacts identified in the risk assessment process are to

be included in an EMP. The EMP should be strategic, describing a framework for

continuing management, mitigation and monitoring programs for the significant

environmental impacts of the Project.

The scope, content and structure of the EMP will be a function of the outcomes

of the environmental risk assessment and determined by the significance of the

environmental impacts. The EMP should not be prepared in isolation but should

be consistent and integrated with the principles of an environmental

management system. The EMP should include specialised management plans

where it is necessary to provide a high level of operational detail. As much detail

Chapter 15

Appendix 19

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Terms of Reference Sections

as is practicable should be provided to enable adequate assessment of the

proposed environmental management practices and procedures.

The EMP needs to address the Project phases (construction, operation and

decommissioning/rehabilitation) separately. It must state the environmental

objectives, performance criteria, monitoring, reporting, corrective action,

necessary resourcing, responsibility and timing for each environmental issue.

Further information on the development of an EMP is available in the NT EPA’s

Guideline for the Preparation of an Environmental Management Plan, accessible

on the NT EPA webpage at: https://ntepa.nt.gov.au/environmental‐

assessments/assessmentguidelines.

15.2 ENVIRONMENTAL MANAGEMENT STRATEGIES

Environmental management strategies have been prepared based on the environmental risks identified in the

Chapter 6, and potential impacts, mitigation measures and monitoring identified in the EIS Part B ‐

Environmental Assessment. These environmental management strategies consolidate and summarise the

commitments made as part of the EIS, and will be used to develop site specific management procedures after

approval of the Project.

Construction and operational strategies to manage potential impacts are summarised below and detailed

further in Appendix 19:

C1 ‐ Erosion and Sediment Control Strategy

C2 ‐ Land and Soils Management Strategy

C3 ‐ Acid Sulfate Soil Management Strategy

C4 ‐ Vegetation Management Strategy

C5 ‐ Weeds and Pests Strategy

C6 ‐ Fauna Management Strategy

C7 ‐ Surface Water Management Strategy

C8 ‐ Groundwater Management Strategy

C9 ‐ Waste Management Strategy

C10 ‐ Air and Noise Management Strategy

C11 ‐ Effluent Management Strategy

C12 ‐ Hazardous Materials Management Strategy

C13 ‐ Traffic Management Strategy

C14 ‐ Social Impact Management Strategy

C15 ‐ Cultural Heritage Management Strategy

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15.3 ENVIRONMENTAL ASPECTS AND IMPACTS

Risk assessment will be conducted as part of each site / phase specific management plan, in order to define site

and phase specific risks, and develop appropriate mitigation and management measures.

Risk assessment follows a standard semi‐quantitative approach consistent with AS/NZS ISO 31000:2009 Risk

Management – Principles and Guidelines. The project risk assessment is outlined in the EIS, Volume 1,

Chapter 6.

15.4 RELEVANT LEGISLATION AND APPROVALS

A Legislation and Approvals Register is required to be developed and regularly updated as part of the project,

outlining the legislation relevant to the Project by jurisdiction, administering authority and relevance. It is

intended to be developed on a site by site basis, and the Legislation and Approvals Register template can be

used for this purpose.

The EIS, Volume 1, Chapter 4 ‐ Approvals, Conditions and Agreements ‐ provides the relevant legislation and

approvals, and will be incorporated into this register once Project approval is gained.

It is the responsibility of the relevant Environmental Manager to ensure the register is up to date, and the

project complies with the legislative requirements of the register.

Project / phase specific management plans are required to reference this register, and determine the specific

impacts of the relevant legislation on that particular project and management plan.

Some sources of information to develop and maintain the register are:

Commonwealth

Federal Register of Legislation

https://www.legislation.gov.au/

Commonwealth Department of the Environment: Legislation

http://www.environment.gov.au/about‐us/legislation

Commonwealth Department of the Environment: Permits, assessments and licenses

http://www.environment.gov.au/about‐us/business‐us/permits‐assessments‐licences

Business.gov.au Environmental legislation (commonwealth and state environmental legislation links)

http://www.business.gov.au/business‐topics/business‐planning/environmental‐

management/Pages/environmental‐legislation.aspx

Northern Territory

Current Northern Territory Legislation Database

http://dcm.nt.gov.au/strong_service_delivery/supporting_government/current_northern_territory_legisla

tion_database

NT EPA Legislation

http://www.ntepa.nt.gov.au/about‐nt‐epa/legislation

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15.5 ROLES AND RESPONSIBILITIES

The general descriptions of the key roles are outlined below, with the organisational structure and specific

personnel included in Appendix 19.

Note where reference is made in this document to the ‘relevant Environmental Manager’, this will be the Chief

Environmental Manager for EMS / corporate level matters or covering all sites, and the relevant site

Environmental Manager for site matters.

15.5.1 Chief Operating Officer

Establish the overall direction of Project Sea Dragon from an environmental perspective, and lead or

support the development of the Environmental Policy

Provide sufficient resources to support the objectives of the EMS

Provide resources for the ongoing review and continual improvement of the EMS.

15.5.2 General Manager ‐ Health, Safety & Environment

Develop and refine environmental objectives, targets and EMS level procedures

Monitor overall EMS performance

Provide input to the ongoing review and continual improvement of the EMS

Ensure site managers have relevant approvals, management plans (i.e. EMP) and licenses to undertake the

works

Ensuring that adequate resources are deployed in a manner to support Site Managers in achieving their

environmental objectives

Develop training materials for EMS / corporate level training requirements.

15.5.3 Site Managers

Responsible for day to day compliance

Ensure that site specific EMPs are implemented on the site

Ensure that personnel and sub‐contractors are appropriately inducted and are aware of requirements of

the EMPs

Relay information to site personnel.

15.5.4 Site Environmental Role ‐ Site Manager, or Delegate

Responsible for developing and implementing site specific EMP

Liaise with Site Manager

Responsible for environmental inspections and monitoring

Develop training materials for site level training requirements and conduct training

Implement non‐conformance processes (incident and complaint management, corrective actions,

notification)

Act as the site contact for governmental officers (Commonwealth, State/Territory, Councils)

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Liaise with environmental consultants when necessary

Lead periodic review and updates of site specific EMP as required.

15.5.5 Site Staff and Sub‐contractors

Adhere to relevant aspects of the site specific EMP (Appendix 19) communicated during inductions, and to

directions given by the Site Manager and Environmental Manager

Have a general duty to not cause environmental harm

Notify their supervisor / employer of any environmental (and other) incidents, near misses and hazards

immediately. Supervisors/employers to ensure the site manager and/or environmental manager is notified

as soon as possible.

15.6 TRAINING AND AWARENESS

Project Sea Dragon Pty Ltd will ensure that all employees are appropriately trained and/or qualified to carry out

their duties. All persons working for or on behalf of Project Sea Dragon Pty Ltd, including staff and contractors,

will be made aware of the environmental policy, and the requirements of the EMS and site specific EMPs. This

will include their role and responsibilities, the significant actual or potential environmental aspects and

associated impacts of their work activities, benefits of improved performance, and the consequences of the

departure from EMS requirements.

Training will comprise the following elements:

Personnel assigned roles within the EMS (including site specific EMPs) will ensure they are appropriately

qualified and experienced

Site induction will be carried out for all new employees and those who have not received such training to

ensure they are appropriately briefed on the relevant aspects of the EMS and the relevant site and phase

specific EMPs

Regular toolbox talks or similar will be held onsite to discuss items and issues of relevance to the EMS.

Form EM‐00‐FO‐001 Training Needs Analysis is provided to identify additional training requirements.

15.7 COMMUNICATION

15.7.1 External Communications

Relations between Project Sea Dragon Pty Ltd and the public are important for maintaining a good working

relationship within the community. Project Sea Dragon Pty Ltd is committed to being a part of the community

as a whole, seeking advice and views as appropriate.

Key points of contact within the organisation for external communication (public, statutory agencies, etc.) are

outlined in the EM‐00‐CT‐0001 Organisational Chart.

The following website will remain the main entry point on the internet for dissemination and communication

with the wider public:

http://seafarmsgroup.com.au/project‐sea‐dragon/

Refer also to Section 15.11 for details of responding to non‐compliance events.

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15.7.2 Board Meetings

Project Sea Dragon Pty Ltd will incorporate the Environmental Policy and EMS Objectives and Targets into

regular management level meetings, communications and discussions, and will implement the management

review process, which reviews environmental objectives and targets, progress towards project aims, changes in

legal and other requirements and the EMS in general. In particular, management will review audit reports, non‐

compliance and project time tables as appropriate.

15.7.3 Internal

At a site level, the results of internal audits, monitoring reports and any non‐compliance will be directed to the

Site Manager / Environmental Manager as they become available. The Site Manager / Environmental Manager

should be advised of any monitoring results or other activity that does not comply with any of the conditions of

development or the EMS / site EMPs as soon as practicable but within at least 48 hrs of the event or receipt of

results (as applicable).

At a corporate level, internal audit and review reports will be circulated amongst the management team and

will form part of board meeting content for discussion and review. Regular site compliance reports will be

reviewed by the General Manager ‐ Health, Safety & Environment, with significant actual or potential issues

raised at the board and/or Chief Operating Officer level.

EM‐00‐CT‐001 Organisational Chart shows the relevant roles and persons, and the preferred communication

channels.

15.8 SUPPLIER AND SUB‐CONTRACTOR MANAGEMENT

Sub‐contractors will be responsible for adhering to the EMS and site specific EMPs, and to directions given by

the Site Manager and Environmental Manager in regards to environmental management.

Sub‐consultants are required to confirm they have policies and procedures in place to allow them to conform

to the relevant aspects of the EMS and site specific EMPs. Procedure [B3] – sub‐contractor management sets

out arrangements to ensure this is undertaken.

The Site Manager must induct each sub‐contractor prior to beginning works on the site.

Each sub‐contractor is to have a nominated contact point to the Site Manager.

15.9 MONITORING AND REVIEW

The key monitoring and review components of the EMS are shown in EM‐00‐RG‐0003 Monitoring and Review.

This outlines the strategic level monitoring required, and elements common to all sites, particularly those

required to report to the Project Sea Dragon Pty Ltd corporate level.

A regular external audit of the EMS and individual sites would also be beneficial as a check against internal

auditing and management of the system and project.

15.10 NON‐COMPLIANCE AND CORRECTIVE ACTION

Non‐compliance with any aspect of the EMS or site specific requirements (including EMPs), the project consent

conditions and/or monitoring limits will require corrective action and reporting. Other incidents such as fire,

unplanned animal release, disease outbreak, or other natural or man‐made incidents should be included. The

type and scale of corrective action and reporting will depend on the type and scale of the non‐compliance.

Generally, non‐compliance will be of the following forms:

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1. Non‐compliance with specific condition of approval, monitoring limit, etc.

2. Non‐compliance with other EMS or EMP requirement or target, including key EMS Objectives and Targets

3. Spills or other incidents causing or with the potential to cause environmental harm (including fire, release

of prawns to the environment, disease outbreak, etc.) (may be captured in items 1 or 2 above)

4. Near miss for the above

5. Complaints.

All of the above items require an incident / complaint / improvement form to be filled out (EM‐00‐FO‐0002).

Corrective actions undertaken at the time of the incident will be described, and additional actions required for

the incident defined when filling out the form. The incident will also be entered into the incidents complaints

register (EM‐0x‐RG‐0004), which assigns actions, responsible person(s), closeout date, and opportunities for

improvement. Improvements or revisions required to EMS documents (including site EMPs) are also to be

included in this register, including as results from audits and reviews.

15.11 COMPLAINTS MANAGEMENT

All complaints and inquiries should be directed to the Environmental Manager. In consultation with the site

manager, the Environmental Manager will assess the validity and seriousness of the complaint or inquiry and

respond as appropriate. Any complaints will be recorded on an incident / complaint / improvement form (EM‐

00‐FO‐0002), and stored within the incidents / complaints / improvement register (EM‐0x‐RG‐0004).

Complaints will be logged with date, time and contact details. The complaint would be forwarded to either the

Site or General Manager ‐ Health, Safety and Environment of Project Sea Dragon Pty Ltd depending on the

nature of the complaint. A response to a complaint during the working week would normally be made within

48 hours.

15.12 DOCUMENTATION AND RECORDS

15.12.1 Document Control

Document control is managed through the use of the document register (EM‐00‐RG‐0001), which is to be

updated when any document is prepared or revised by the author of that document. The register is under the

primary responsibility of the Chief Environmental Manager, but will be edited by site Environmental Managers

to add site specific documents.

Release of new documents for the system is to be approved by the immediate Environmental Manager for that

document, namely:

For EMS / corporate level documents, the Chief Environmental Manager

For site specific documents, the Site Environmental Manager.

Any document not signed and authorised for release is not considered a current document for the purposes of

the EMS. It is the responsibility of the author of a document (new or revision) to obtain approval for release

from the relevant Environmental Manager.

The document control page from this manual (page after the cover page) is to be present for all system

documents other than forms and registers. In all cases, headers and footers are to contain the same

information as in this document, including:

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Document name

Document reference

Revision

Date Printed

A note stating that Printed copies are uncontrolled

Page number and number of pages

Only current documents shall be in use and it is the responsibility of the relevant Environmental Manager to

ensure that any updates are propagated as required to the points of issue and any old issues are taken out of

circulation. Primary controlled documents will be maintained electronically on the project intranet, with

revised copies superseding older copies of documents. These older documents will be moved to an ‘archive’

folder.

Any changes in documentation or legislative or other requirements will be followed by a review by the relevant

Environmental Manager (or by the report author, communicated to the relevant Environmental Manager) of

the possible impacts on the remainder of the system and changed where necessary. The scale of this review

will depend on the nature of the changes.

15.12.2 Document Numbering

The documentation numbering scheme is as shown below. Where site specific documents are required in

addition to the EMS level document, such as the Monitoring and Review register, these are to take the same

numbering as the EMS level document, regardless of the number of site level documents (e.g. EMS level = EM‐

00‐0003, site level = EM‐01‐0003).

[Aspect]‐[Site]‐[Doc Type]‐[Doc Number][revision] [Short name]

e.g. EM‐00‐RG‐0001b Document Register, EM‐01‐MP‐0001a‐CBC and BMC Facility EMP

Where:

[Aspect] = Selected from the following list:

EM = Environmental, generally all EMS documents, but allows for other quality level or WHS documents to use

the same numbering system

[Site] = site code, selected from the following list:

00 = EMS level (no / all sites)

01 = CBC and BMC Facility

[Doc Type] = Document type, selected from the following list:

RG = Register

MN = Manual

CT = Chart (e.g. organisational chart)

FO = Form

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MP = Management Plan (e.g. construction environmental management plan)

[Doc Number] = consecutive numbering for this type of document, as 4 numerals starting at 0001

[revision] = lower case letters (a, b, c etc.) for drafts, and numerals (0, 1, 2, 3, etc.) for issued documents

[Short name] = a very short name to aid in identification, generally less than 24 characters including spaces

15.12.3 External Documents and Standards

Preferably, standards and guidelines will be sourced directly from the primary source when accessed, rather

than from locally stored copies. Where locally stored copies are stored and used, it is the responsibility of the

relevant Environmental Manager to maintain the latest copies of such documents for use.

SAI Global Standards Watch is a useful tool for keeping apprised of updates to relevant standards:

https://infostore.saiglobal.com/store/AboutSWatch.aspx.

15.12.4 Records

Relevant documentation shall be retained as records within the EMS system, stored on the project intranet.

These records shall include (but not be limited to):

information on compliance, including audit and review (internal or external) reports or forms

details of nonconformities and corrective and preventive actions, including Non‐conformance forms and

the incident/complaint/improvement register

evidence of fulfilment of objectives/targets, including review / audit reports

information on participation in training, including training needs analysis forms (copies of each update

saved separately with date)

permits, licences or other forms of legal authorization,

results of inspection and calibration activity and

results of operational controls (maintenance, design, manufacture).

15.13 REPORTING

Reporting requirements are detailed in the EM‐00‐RG‐0003 Monitoring and Review register and site specific

Monitoring and Review registers (e.g. EM‐01‐RG‐0003 Monitoring and Review).

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