• Coastal and offshore resource infrastructure development is occurring in a time of increasing reliance on our coasts and oceans to provide ecosystem services to humans – ie food, air and

water.

• An already strained ecosystem is at an increased risk of not delivering these ecosystem services to humans into the future due to factors such as climate change, population increase,

and pollution from the increasing globalisation of society and the economy.

• Without ecologically sustainable economic development and use of coastal and ocean energy resources that provides an economic buffer in transitioning to renewable energy into the

future we cannot hope to adapt and minimise the impact of global and local environmental change on society.

• The development of Environmental Plans provides for a risk-based approach to sustainability

and the complex relationship between people, resources and the natural world that ensures industry is accountable for its actions in providing services to humans.

• Under the OPGGS Act 2006, the 2009 Environment Regulations follow the Principles of

Ecologically sustainable economic development (Reg 3). Where a petroleum activity is being carried out (Reg 4(1)) an EP must be submitted.

1

• The 2 main components of an EP are:- environmental assessment (planning phase); and

- implementation strategy (operational phase).

• The 2009 Regulations governing submission and acceptance of EP’s are consistent with system-based approaches described in AS/NZS standards ISO 14001 Environmental

Management Systems and ISO 31000 Risk Management – Principles and Guidelines.

• An EP should capture:- a description of the activity, environment, regulations, impacts and risks and

detail the impacts and risk of the activity. It should evaluate and demonstrate that impacts and risks are acceptable and reduced to ALARP. It should define performance objectives

and standards and measurement criteria that capture performance and monitoring and standards and measurement criteria that capture performance and monitoring requirements. It should include consultation, an implementation strategy and any additional

content required.

• The complexity of coastal and ocean resource development can be represented in Chevron’s Wheatstone project, bringing ashore LNG from offshore wells and associated infrastructure.

• At every stage of exploration, construction and operation, environmental impacts have to be

managed and the potential for significant and often cumulative adverse effects mitigated against.

• Drilling, installing equipment and production facilities, seismic surveying, pipe laying,

dredging, trenching, rock piling, or servicing and maintaining production infrastructure and its use - they all have an existing or potential impact on the surrounding environment.

2

• This presentation will cover (see PowerPoint)

• The presentation focuses in particular on the regulatory environment and approvals process in regard to preparation, assessment and acceptance of EP’s as in force plans.

• An EP has to demonstrate compliance with the criteria in Reg 11(1):

(1) The Regulator must accept the environment plan if there are reasonable grounds for

believing that the plan: (a) is appropriate for the nature and scale of the activity or proposed use; and

(b) demonstrates that the environmental impacts and risks of the activity will be reduced to as low as reasonably practicable; and

(c) demonstrates that the environmental impacts and risks of the activity will be of an (c) demonstrates that the environmental impacts and risks of the activity will be of an acceptable level; and

(d) provides for appropriate environmental performance objectives, environmental performance standards and measurement criteria; and

(e) includes an appropriate implementation strategy and monitoring, recording and reporting arrangements; and

(f) for the requirement mentioned in paragraph 16 (b) — demonstrates that: (i) the operator has carried out the consultations required by Division 2.2A; and

(ii) the measures (if any) that the operator has adopted, or proposes to adopt, because of the consultations are appropriate; and

(g) complies with the Act and the regulations.

3

• Also covered (see PowerPoint)

• In particular, the presentation covers the components of assurance and compliance and how this relates to the need to demonstrate a risk-based approach to resource developments.

• Division 2.3 of the Environment Regulations outlines the EP development process in a

coherent and systematic way. This approach provides a strong link to risk management systems developed by

• recognised bodies such as ISO and AS/NZS.

• EP environmental assessment: The environmental assessment component of an EP is focused around a process to demonstrate that environmental impacts and risks are of an

acceptable level and ALARP.acceptable level and ALARP.

• EP implementation strategy: The core elements are:1. measures to ensure environmental performance objectives and environmental

standards are met2. systems, practices and procedures to ensure impacts and risks are continuously

reduced to ALARP3. chain of command, including roles and responsibilities

4. measures to ensure personnel are competent and trained5. provisions for monitoring, auditing, management of non-conformance and review

6. provisions for the maintenance of accurate quantitative records of emissions and discharges

7. an OSCP including emergency response and testing arrangements8. provisions for ongoing consultation

4

• The aim of this presentation (see PowerPoint)

• Specifically, the presentation’s objective relates to how to prepare an EP that covers off all the content requirements while also being structured in such a way as to meet assessment

criteria.

• The regulatory process and elements provide a framework that allows operators to apply a systematic approach to meeting the EP requirements of the Environment Regulations.

• The EP process step to “Describe” [sub-regulations 13(1) and (2)] applies to the elements

“activity” and “environment”. So, to meet the regulatory requirements, an EP must “Describe the Activity” and “Describe the Environment” as laid out in the Environment Regulations.

5

• In considering EP’s feedback on the new regulatory arrangements for EP’s, and EP’s in general was obtained by liaising with operator HSE specialists.

• The approach the regulator takes in administering the regulations was also considered

against content requirements to gain insight into how this approach impacts the activity operator when preparing an EP.

• The EP process and key elements include:

1. Describe 4(1), 5, 6, 11(1) 13(1), 13(2), 13(5): Activity, Environment, Requirements,

Acceptable level(s)2. Detail 4(1), 8(1), 13(3): Impacts and risks

3. Evaluate and demonstrate 4(1), 11(1),13(3), 13(3A), 14(3): Impacts and risks –3. Evaluate and demonstrate 4(1), 11(1),13(3), 13(3A), 14(3): Impacts and risks –acceptable level(s), Impacts and risks - ALARP

4. Define 3(b), 4(1), 11(1), 13(4): Environmental performance objectives, Environmental performance standards, Measurement criteria

5. Consultation 11(1), 11(8), 11A, 14(9), 16(b): Stakeholder consultation6. Implementation strategy 14

7. Additional content requirements (Regulations 15, 16, 26, 26A, 26AA,26B, 29 &29A)

that must be reflected in an EP.

6

• Evidence of need covers off 4 key areas, these being (see PowerPoint).

• The Environment Regulations are:1. objective-based, where general requirements are provided. The operator is

responsible for determining their approach to meeting these requirements;2. risk-based, where a central part of the EP is the assessment and management of the

environmental impacts and risks of the activity;3. performance-based, where appropriate environmental performance objectives and

environmental performance standards are in place that have measurement criteria to determine if they are being met; and

4. system-based, where a structured risk management process is applied to developing the EP which shows the continual and iterative steps that are followed to assess and

manage environmental impacts and risks effectively.manage environmental impacts and risks effectively.

• The operator of an activity owns the EP. NOPSEMA’s role is one of assessing and deciding to ‘accept’ or ‘refuse to accept’ the operator’s EP and subsequently monitoring the operator’s

continued compliance with the EP.

7

• The object of the Environment Regulations, as set out in Regulation 3, is to ensure that petroleum activities are carried out in a manner that is consistent with the principles of

ecologically sustainabledevelopment; and in accordance with an EP that has appropriate environmental performance

objectives, standards and measurement criteria for determining whether the objectives and standards

have been met.

• The context behind the evidence of need to address the complexities of EP preparation and approaches to acceptance can be divided into 9 key points, these being (see PowerPoint).

8

• For an EP to be accepted, the operator must address the regulatory requirements in a way that provides NOPSEMA with reasonable grounds to believe that the requirements have

been, or will be, met. Thisshould be supported by well-documented evidence.

• To determine if an EP meets the requirements, operators should consider:

1. � Does the EP clearly demonstrate that the criteria in Regulation 11(1) have been met?

2. � Is the demonstration supported by adequately justified statements?3. � Are all statements made to support the demonstration sufficiently supported by

evidence or appropriate references, such that NOPSEMA can reasonably determine their accuracy and reliability?

4. � Is a clear basis provided for environmental performance objectives, environmental 4. � Is a clear basis provided for environmental performance objectives, environmental performance standards and measurement criteria and are they appropriate to: the

protection of the affected environment, identified environmental impacts and risks and their related control measures?

5. � Are the environmental performance objectives and environmental performance standards specific and measurable (e.g. S.M.A.R.T. - specific, measurable,

achievable, relevant, time-based)?6. � Is it clearly demonstrated how, when, where and why control measures will be

implemented, monitored and reported against?7. � Does the implementation strategy include the specific systems, practices and

procedures that describe how environmental performance will be measured over the life of the activity?

8. � Does the implementation strategy clearly demonstrate the systems that are in place to implement, check and review activities (including management measures) in

compliance with the EP?

9

• The types of coastal and offshore construction activities requiring an EP may consist of:1. Dredging – deepening shipping channels, sediment and rock piling for ports and

wharfs, marina’s, land reclamation2. Trenching – burying pipelines into the seafloor, burying or overlaying coastal areas

such as beaches, intertidal areas, mangroves3. Construction – infrastructure development for energy projects, wharfs, wells, pipes,

processing, transport etc4. Production – various types of production including subsea, floating LNG, manned and

unmanned WHP’s etc5. Seismic surveys -

• The environmental assessment component of an EP is focused around a process to

demonstrate that environmental impacts and risks are of an acceptable level and ALARP. demonstrate that environmental impacts and risks are of an acceptable level and ALARP. Environmental performance objectives and environmental performance standards, and their

measurement criteria, are defined and set respectively to ensure overall environmental performance is maintained at the defined acceptable and ALARP levels.

• The implementation strategy core elements required to meet this are:

1. � measures to ensure environmental performance objectives and environmental standards are met

2. � systems, practices and procedures to ensure impacts and risks are continuously reduced to ALARP

3. � chain of command, including roles and responsibilities4. � measures to ensure personnel are competent and trained

5. � provisions for monitoring, auditing, management of non-conformance and review6. � provisions for the maintenance of accurate quantitative records of emissions and

discharges7. � an OSCP including emergency response and testing arrangements

8. � provisions for ongoing consultation

10

• All these types of activities require preparation of an EP where although the context is different, it has to meet the same assessment criteria.

• Unravelling the complexity of such arrangements regarding EP content and preparation will

assist in understanding how to simplify approaches to acceptance of an EP as an in force plan.

• The Environment Regulations simply reflect the “plan – do – check – act” cycle that is the

basis of a systematic approach to environmental management. The Environment Regulations provide a framework in which this basic process is conducted and are designed to ensure

appropriate and sufficient oversight. Consequently, the Environment Regulations provide the basic process and critical steps against which operators need to demonstrate their

compliance with the regulatory requirements including the “plan – do – check – act” cycle.compliance with the regulatory requirements including the “plan – do – check – act” cycle.

11

• Requirements regarding the content of an EP appear relatively straight forward at first glance and should include (see PowerPoint). The process for developing an EP can be described as

having two distinct components – the environmental assessment and the implementation strategy.

12

• However, the manner in which an EP is prepared is not easily discernable and left to the operator to decide. Neither the regulations nor the regulator outlines any specific

requirements as to the approach that should be taken in preparing or presenting the required content.

• The key process steps (describe, detail, evaluate and demonstrate, define, consultation and

implementation strategy) that are provided for in the Environment Regulations for developing an EP.

• The Environment Regulations also include the particular elements that these process steps

relate to, and which further describe the EP requirements of the Environment Regulations.

13

• The regulations do outline what an EP is assessed against, but bridging the gap between required content and alignment with the regulations for assessment successfully depends on

how content is structured and presented. Here required content is covered in more detail and then related to document preparation for assessment.

• Relevant Regulations Assessed Against are:

1. Activity: 4(1) (definition of activity), 5, 6, 11(1)(a), 13(1)(a-d)2. Environment: 4(1) (definition of environment), 11(1)(a), 13(2) (a)(b)

3. Other legal requirements: 13(5) (a)(b), 11(1)(a)4. Acceptable levels of impacts and risks: 11(1)(c) (also see section 3.6 “Evaluate and

Demonstrate: Impacts and Risks - Acceptable Level”)5. Impacts and Risks: 4(1) (definition of environmental impact), 13(3)(a), 8(1)

6. Evaluate and demonstrate impacts and risks: 4(1) (definition of environmental 6. Evaluate and demonstrate impacts and risks: 4(1) (definition of environmental impact), 11(1)(c), 13(3)(b), 13(3A)(a)(b)

7. Evaluate and demonstrate impacts and risk are ALARP: 11 (1) (b), 14 (3)8. Define Environmental Performance Objectives: 3(b)(i)(ii), 4(1) (definition of

environment, environmental performance, environmental performance objective and recordable incident), 11(1)(d), 13 (4)(a)(b)(c)

9. Define Environmental Performance Standards: 3 (b)(i)(ii), 4(1) (definition of environmental performance standard and recordable incident), 11(1)(d), 13

(4)(a)(b)(c)10. Define Measreument Criteria: 3 (b)(i)(ii), 4(1) (definition of environmental

performance objective and environmental performance standard), 11(1)(d), 13 (4)(a)(b)(c)

11. Stakeholder Consultation: 11(1)(f), 11(8)(a)(vi), 11A, 14(9), 16(b)12. Implementation Strategy: 14(1-10)

13. Additional Content Requirements: 15, 16, 26, 26A, 26AA & 26B, 29, 29A

14

• Perhaps a key aspect underpinning EP content is the requirement to demonstrate consultation (see PowerPoint).

• The EP must include details of the consultation conducted during the development of the EP

[11(1)(f)] and also include a plan for ongoing consultation during the operational phase [14(9)].1. The EP must demonstrate that the operator has carried out the required consultations

in the required manner [11(f)(i)].2. The EP must demonstrate that the measures (if any) that the operator has adopted,

or proposes to adopt, as a result of the consultations are appropriate [11(f)(ii)].3. For consultation in the course of preparing the EP, the operator must consult relevant

persons [11A].4. The EP must contain a report on all consultations between the operator and a

relevant person [16(b)] and that report has specific requirements [16(b)(i-iv)].relevant person [16(b)] and that report has specific requirements [16(b)(i-iv)].5. The implementation strategy must contain a plan for appropriate consultation on an

ongoing basis with relevant stakeholders (Commonwealth, state or territory authorities and other interested persons

6. or organisations) during the operational phase of the activity [14(9)].7. Consultation in preparation of an EP may help inform the operator about what is

considered to be an ‘acceptable level’ of environmental impact and risk.8. The consultation must be appropriate for the nature and scale of the activity in that all

persons whose functions, interests or activities may be affected by the activity must be consulted.

15

• The operator should consider and provide a reasonable basis for determining who they consider to be ‘relevant persons’ and define these in the EP. While “relevant person” is

described in the Environment• Regulations, the operator must determine in the context of nature and scale of the activity,

which persons may be relevant and whose functions, interests or activities may be affected by the activities

• to be carried out under the EP.

• Stakeholders can consist of any person, organisation, ethnic group or industry that may potentially be adversely affected by an activity. Examples are:

1. Fishing industry2. Aquaculture industry

3. Indigenous people3. Indigenous people4. Conservation groups

5. Recreational user groups6. Government (matters of national interest)

7. Public 8. Military

16

• Of particular importance is the requirement for consultation regarding development of an Oil Spill Contingency Plan. Evidence of this consultation has to be shown in the preparation of an

EP.

• It is essential to liaise with those involved in implementing the National Plan, which is aligned with MARPOL requirements for spill response, escalation, and a 3-tiered approach to dealing

with an unplanned event. This is covered in more detail later (see section 2.4.1, 2.4.2, 2.4.3).

• In cases where it is appropriate to the nature and scale of an activity, operators could undertake consultation for a range of petroleum activities on a strategic basis. The submission

for each activitywould need to demonstrate that this action was appropriate and that each identified relevant

person had sufficient time and information to make an informed assessment of the potential person had sufficient time and information to make an informed assessment of the potential impacts of the

specific activity on their functions, interests or activities.

17

• When an activity has the potential to impact on matters of national interest a referral to the Minister of Resources, Energy and Tourism has to be made for assessment. It is a

requirement under the Environmental Protection, Biodiversity and Conservation Act 1999 (see PowerPoint).

18

• Assessments are made from (see PowerPoint).

• The EP must describe the regulatory and other requirements that apply to the activity and are relevant to the environmental management of the activity. Requirements should be included

as part of the context of the activity to help understand the regulatory and other requirements that may influence the way in which an activity is assessed and managed by the operator.

• Requirements include other approvals, legislative requirements or conditions that may apply

to the specific activity.

19

• An Environmental Impact Statement has to be prepared that addresses the effects of the activity or project. Key to an EIS is that it provides for alternatives and an opportunity for

public participation or consultation. Also key is that the Minister must refer the EIS to the Environmental Protection Agency for assessment.

• Activities that have the potential to impact on sensitive areas may include:

1. Oil and Gas Exploration and production near MPA’s and Marine Park coral reefs, deep ocean habitats, nursery grounds etc

2. Oil and Gas Exploration and production near whale migration routes3. Oil and Gas Exploration and production near turtle nesting sites

4. Coastal processing facility development and associated wharf/port structure near culturally significant sites

5. Coastal processing facility development and associated wharf/port structure near 5. Coastal processing facility development and associated wharf/port structure near MPA’s or marine parks

6. Operations near or in commercial fishing areas7. Vessel or facility movement and / or subsea construction biofouling and introduced

marine pests or native invaders

20

• EP requirements could include amongst other things: relevant laws, codes, standards, agreements, treaties, conventions or practices that apply to the jurisdiction that the activity

takes place in, or otherjurisdictions, that may be relevant to the activity.

• The description of requirements should not just be presented as a list of requirements, but

should provide details of which requirements are relevant to the specific activity in the EP and how they apply to the activity. The description of requirements forms part of the context of the

activity and influences the assessment and management of the activity, and the development of environmental performance objectives and environmental performance standards.

• These requirements should be taken into account in establishing, implementing and

maintaining environmental management of the activity. Requirements that are not relevant to maintaining environmental management of the activity. Requirements that are not relevant to the environmental management of the activity do not need to be included.

21

• Commonwealth environmental regulatory reform is underway to streamline the approvals process and provide for one application and assessment process, particularly in dealing with

biodiversity offsetting for mining and energy development.

• This will limit the burden on the proponent in preparing submissions for assessment and referral for matters of national significance.

22

• Alongside commonwealth regulatory reform the WA EPA under the Environmental Protection Act 1986 allows for environmental offsets to be incorporated into the EIA process as part of

preparation of an EIS for referral. ie activities potentially impacting on matters of national significance can be ‘offset’.

23

• One of the most important features of an EP is the implementation strategy, which provides assurance to the regulator that all necessary precautions have been taken to ensure that any

potential or existing impacts have been reduced to As Low As Reasonable Practicable (ALARP). As a function of this strategy the proponent has to show in any referral that they are

able to manage such impacts.

• The implementation strategy includes specific requirements [Reg 14 (4-10)] that must be addressed in the EP for the duration of the proposed activity. These include: chain of

command, responsibilities, trainingand competence, monitoring, auditing, management of non-conformance and review of

environmental performance and the implementation strategy, quantitative records of emissions and discharges, an OSCP, consultation and regulatory compliance.

• An OSCP must be included as a component of the implementation strategy. The OSCP must

contain specific emergency response and testing arrangements that are appropriate to the impacts and risk of the activity under emergency conditions.

24

• The implementation strategy must provide for appropriate consultation with relevant government agencies, relevant interested persons and organisations for the life of the activity

or five-year EP review period. (see section 3.11: Consultation)

• A critical element of this strategy is the Oil Spill Contingency Plan. Being a ‘operational’ document it provides the necessary detail that ensures compliance with EP assessment

criteria. An OSCP brings together a wide range of EP components, from EIA and baselines studies where knowledge is lacking, to Zone of Potential Impact (ZPI) modelling and

responses to an unplanned event offshore and onshore.

• Provisions for periodic review of environmental performance and the effectiveness of the implementation strategy should be detailed. This review cycle should allow the operator to

determine if the measures, systems, practices and procedures of the implementation strategy determine if the measures, systems, practices and procedures of the implementation strategy have been effective in ensuring that performance objectives and environmental performance

standards have been met and that impacts and risks are consistently being managed to acceptable levels and reduced to ALARP as defined in the EP.

25

• In preparing an OSCP consideration should be given to (see PowerPoint)

26

• Sources of spill events can be from activities where unplanned events occur, such as:

1. A collision, grounding or foundering2. A well blowout

3. A pipeline incident

• Causes may be related to any number of events, but the circumstances surrounding them are always viewed from a risk and safety assessment perspective. Irrespective of the source, the

impacts have a commonality about them that is directly related to the scale of the event.

• Right side of the slide shows the position of the Montara blowout and associated oil slick. Left side shows vessel incidents and associated oil slicks. Circumstances surrounding the source

of the event interact with the nature of the environment and determine the scale of impact.of the event interact with the nature of the environment and determine the scale of impact.

27

• Impacts can be broadly defined as those occurring offshore and at sea and those that affect the coastline, whether originating from offshore, coastal or onshore.

• Offshore: depending on the scale of the event it has the potential to affect entire food webs. For example the Montara blowout cumulative impact on the environment was the size of the state of West Virginia. Over such broad spatial scales Oil type, toxicity (PAH’s), viscosity, specific gravity, aging and weathering have significant implications for the degree of temporal impact (impact over time) on localised offshore primary production and flora and fauna.

• Impacts of a major event include:1. Transient fish, invertebrate, turtle and mammal populations can be smothered, gill fouled and/or ingest

weathered oil. 2. Consumption and accumulation up the food chain can occur – localised collapse of food web due to

inhibition of primary production because of photoinhibition and altered behaviour (phytoplankton and zooplankton populations).

3. Deep ocean impacts from event aged fuel breakup and deposition to the deep ocean seafloor via the carbon cycle.

4. Abundance in biogenic sediments and accumulation through benthic primary producer food chain in deep ocean habitats – effect unknown.

5. Upwelling and re suspension due to seasonal cycling, long term disruption to food webs and trophicstructure across broad spatial scales.structure across broad spatial scales.

28

• Onshore: impacts onshore are immediately more obvious and pronounced and can be initially related to smothering of marine fauna and flora. Initial impact of uptake of toxic PAH’s on

aquatic health depends on the rate of weathering and type of organism. Ie filter feeder, infauna, epibenthic, carnivore, herbivore and whether they are a bird, mammal, crustacean,

mollusc, echinoderm etc and the manner in which they reproduce (broadcast spawner, brooder, etc).

• Different habitats will mediate an organisms response to an oil slick and may include:

1. Surf zone beaches – accumulation through successive tidal cycles, increased breakup and aging, smothering and seeping into sub layers of sand.

2. Rocky coastline – topographically complex means accumulation of weathered oil is more difficult to get rid of and effects may be long-lasting in this regard.

3. Mangroves – almost impossible to remove trapped oil without removing forest. 3. Mangroves – almost impossible to remove trapped oil without removing forest. Breakdown may be faster though because of the nature of mangroves and

entrapment and binding up of sediment.4. Harbour and other estuaries – ecologically very sensitive, especially if already heavily

modified due to anthropogenic activities. Oil can become trapped between tidal cycles and never wash out, depending on degree of flushing.

• Long-term impacts include the sub-lethal and chronic effect of toxicity (PAH’s and endocrine

disruption), reproductive inhibition, and recruitment failure, population change and dislocation. Often unintended consequences occur ie larval supply to other unaffected areas etc, or

nursery grounds for local populations wiped out, esp. fish.

29

• A key aspect of preparing an EP is to show how an activity will be monitored and how any potential impact will be assessed. To meet this requirement it is essential that the risk

assessment process has been addressed in preparing the EP and that evidence of this has been provided. Measurement criteria must be developed and standards also developed to

demonstrate compliance with the EP and its requirements.

• Some operators may integrate the preparation of an EP within an existing Environmental Management System (EMS) and its certification or development under ISO14001.

• ISO 14001 is an internationally accepted standard that sets out how you can go about putting

in place an effective Environmental Management System (EMS). The standard is designed to address the delicate balance between maintaining profitability and reducing environmental

impact; with the commitment of the entire organization, it can enable the achievement of both impact; with the commitment of the entire organization, it can enable the achievement of both objectives.

• What’s in ISO 14001:

1. General requirements

2. Environmental policy3. Planning implementation and operation

4. Checking and corrective action5. Management review

30

• The risk assessment process is in alignment with AS/NZS ISO31000 which replaces AS/NZS 4360. Risk assessment has to include identifying the risks, analysing likelihood and

consequence, prioritising the risks, and risk treatment.

• It is a requirement by NOPSEMA for environmental risk assessment to address both inherent risk with no controls in place and to show that the post-treatment risk has been reduced to

tolerable or with additional controls in place to As Low As Reasonable Practicable (ALARP).

• A great software programme now available to achieve this is PHA Pro 8, which allows the user to enter a risk matrix which is then linked to the spreadsheet used during a workshop.

31

• Risk is defined as the ‘effect of uncertainty on objectives’ (AS/NZS ISO 31000:2009). The objectives can be financial, health and safety, environmental and so on. The risk management

process involves the following steps, as given in ISO 31000:2009:

1. setting objectives and establishing the context of the risk assessment;2. identifying the risks;

3. analysing the risks to determine the level of risk, which is defined as the combination of the consequences and likelihood of the risk;

4. evaluating the risk, to decide if a risk is acceptable, tolerable or intolerable / unacceptable;

5. treating the risks, focusing on those risks which are intolerable; and6. monitoring and review, to continuously refine and improve the assessment and risk

treatments.treatments.

32

• A typical risk matrix against which activities are assessed consists of:

1. A scale of severity and associated consequences in terms of people, property and the environment

2. A scale of the frequency of occurrence with associated definitions3. The response matrix showing whether the risk is low/tolerable, medium/ALARP, or

high/intolerable

• Provisions for monitoring environmental performance and the implementation strategy against performance standards and objectives identified through the risk assessment process

throughout the operational phase of the activity must be included. Monitoring should be sufficient to identify deviation in environmental performance from the levels set in the EP. The

frequency and type of monitoring should be appropriate to the nature and scale of the activity.frequency and type of monitoring should be appropriate to the nature and scale of the activity.

33

• Monitoring programmes need to address both the potential for proximate operational environmental impacts while providing assurance that in the event of a major spill or other

event the wider environment has been considered.

• A monitoring plan needs to take into account the potential for spills to come ashore, account for lack of information by conducting baseline studies, and providing for ongoing monitoring. It

also has to consider that in the event of a spill a rapid response survey can be conducted both in proximity to the spill and other areas where a spill is likely to come ashore.

• Real time monitoring is also crucial, especially in terms of met-ocean data, and modelling and

prediction of downstream events and impacts from a spill.

34

• Baseline studies and modelling requires careful consideration of sampling and survey design to achieve a balance between reliability and cost.

• Before, After, Control, Impact designs optimise the opportunity to detect any potential

environmental impact, the details of which are the subject of an entirely separate seminar.

• Needless to say that the natural world is full of background ‘noise’, which can easily mask the ability to detect impacts if sampling designs do not adequately account for this ‘noise’.

• The chance of false negatives is relatively high and requires rigorous power analysis and

testing to minimise or limit this from occurring should a result show no impact. ie there really was NO impact!

• A complimentary sampling regime may involve real time integrated monitoring, which

provides a rigorous picture of an area over time but may have limited use spatially depending on cost. However, it may be quite useful for operational monitoring.

35

• Advances in Radiotelemetry mean technology, hardware, and software is becoming available to use remotely for real time monitoring in environments that are often difficult to work in.

• May involve time-lapse video of the seafloor and water column, sensors for sampling water

parameters, sea surface variables, seabed shifts and disturbance etc.

• Able to detect changes in habitat composition, community composition, fauna behaviour, seawater nutrient levels, turbidity and current, seawater chemical composition etc.

36

• All arriving international vessels are required to manage their ballast water in accordance with the Australian ballast water management requirements. The DAFF website provides further information to assist operators comply with the requirements.

• A comprehensive set of domestic ballast water management arrangements are being developed under the National System to complement the existing requirements for international vessels. These arrangements will be consistent with the International Maritime Organization’s International Convention for the Control and Management of Ships' Ballast Water and Sediments, which Australia has signed subject to ratification.

• The risk of the petroleum production and exploration industry spreading marine pests is highest when vessels, immersible equipment and infrastructure:

1. are heavily biofouled and organisms such as mussels, oysters, seaweeds and seasquirts are visibleseasquirts are visible

2. are moved to a new area after spending long periods either stationary or at low speeds (including undergoing dockside upgrades)

3. have areas without antifouling coating or the coating is inappropriate for vessel use, aged or worn.

37

• Risk can be reduced by incorporating practices that minimise the build up of biofouling into your routine

cleaning and maintenance programs. The 'National biofouling management guidance for the petroleum

production and exploration industry' document outlines practical recommendations for operators on

managing biofouling on petroleum related vessels, equipment and infrastructure. These

recommendations have been developed in conjunction with the petroleum production and exploration

industry and apply to the following vessel types:

1. offshore support vessels including utility support vessels, platform supply vessels and anchor

handling tug supply vessels

2. mobile offshore drilling units including jack-up units, drilling barges and semi-submersible ships

3. crew transfer vessels

4. diving support vessels

5. accommodation vessels

6. seismic survey vessels6. seismic survey vessels

7. landing craft

8. pipelay ships and barges

9. floating production, storage and offloading vessels (FPSO) and floating storage and offloading

vessels (FSO).

• Operators of oil tankers and gas carriers should refer to the 'National biofouling management guidelines

for commercial vessels' for guidance on managing biofouling. Operators of heavy lift vessels and

dredges (including rock dumping ships) should refer to the 'National biofouling management guidance

for non-trading vessels' for further information on managing biofouling. The 'National biofouling

management guidance for the petroleum production and exploration industry' also inlcudes information

on biofouling management of submersible equipment and infrastructure.

38

• Monitoring programmes may consider:1. Permanent sea surface sensors

2. Permanent satellites and GIS 3. Permanent seafloor sensors

4. Water column deployed and towed equipment5. Periodic remote surveys

6. Periodic surveys7. Predictive modelling

8. Structures, fouling and marine pest management

39

• Key elements contributing to an EP need to be bought together in a coherent and succinct manner for submission and assessment against the regulations and acceptance as an ‘in

force’ plan.

40

• Key in preparing the EP structure is to provide evidence of assurance and compliance (see PowerPoint).

• Provisions for management of non-conformance must also be detailed in the implementation strategy.

• These provisions should allow sufficient information to be collected to fulfil regulatory requirements for reporting of recordable and reportable incidents to the regulator and to

ensure that any corrective and preventative actions are implemented.• Provisions for periodic review of environmental performance and the effectiveness of the

implementation strategy should be detailed. • This review cycle should allow the operator to determine if the measures, systems, practices

and procedures of the implementation strategy have been effective in ensuring that performance objectives and environmental performance standards have been met and that

impacts and risks are consistently being managed to acceptable levels and reduced to impacts and risks are consistently being managed to acceptable levels and reduced to ALARP as defined in the EP.

41

• To recap on the regulations, the key to successful assessment is under division 2.2 and 2.3 of the 2009 regulations (see PowerPoint). Key aspects related to successful assessment also

include:1. The EP must include arrangements for recording, monitoring and reporting a

sufficient level of information to allow the operator to demonstrate to the regulator that all of the environmental performance objectives and environmental performance

standards in the EP have been met. 2. Reporting arrangements must address reportable incidents, recordable incidents and

routine environmental performance reporting.3. The EP must include details of all the reportable environmental incidents that may

arise from the proposed activity.4. Intervals for environmental performance reporting in accordance with the Regulations

must be provided in the EP such that they can be agreed to by the regulator.must be provided in the EP such that they can be agreed to by the regulator.5. he EP must detail the arrangements put in place by the operator for notification of the

relevant state or territory minister of the commencement of drilling or seismic survey activities if those activities may have an effect on a community in the activity

area.6. The EP must contain a statement of the operator’s corporate environmental policy.

7. The EP must contain a report on consultations (see section 3.11: Consultation).8. The EP must address the specific requirements for the discharge and testing of

produced formation water.

42

• In bringing these elements together, the assessment criteria and regulations can be matched against submission structure by following the Safety Case Approach to submissions and

approvals (see PowerPoint).

43

44

45

• What does the future hold:

• Alignment with EMS ISO 14001 both from a regulator and operator perspective. Future legislation and government policy objectives may seek to reflect this arrangement.

• Environmental impact is becoming an increasingly important issue across the globe, with

pressure to minimize that impact coming from a number of sources: local and national governments, regulators, trade associations, customers, employees and shareholders. Social

pressures are also building up from the growing array of interested parties, such as consumer, environmental and minority non-governmental organizations (NGOs), academia

and neighbours.

• So ISO 14001 is relevant to every organization, including:• So ISO 14001 is relevant to every organization, including:1. Single site to large multi-national companies

2. High risk companies to low risk service organizations3. Manufacturing, process and the service industries; including local governments

4. All industry sectors including public and private sectors5. Original equipment manufacturers and their suppliers

46