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Expert Witness Statement t 01.doc Final 30-09-2020 Version 01

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Review of the AGL Gas Import Jetty and Project Environmental Effects Statement

Gas Import Jetty Works; Construction and Operations

Expert Witness Statement 01

Routine and Non Routine Marine Discharges, Effects and Management

Presented By John A Wardrop

28 Station Street, Drysdale, Victoria 3222

30/09/2020


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Disclaimer

This report has been provided at the request of Submitter No. 3088.

It is based on a review of documents supplied by the Proponents online:

https://www.gasimportprojectvictoria.com.au/sites/default/files/2020-

06/GIJPP%20EES%20Technical%20Report%20K%20Safety%2C%20hazard%20and%20risk%20assessments.pdf.

All views, comments, queries and assessments are those of the author, John Wardrop.


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Table of Contents

1.0 INTRODUCTION 5 1.1 Purpose of this Report 5 1.2 Rationale and Methodology 5 1.3 Report Structure 6 1.4 Statement Limitations 7 1.5 Key EES Documents and Sections Reviewed 8 2.0 IDENTIFICATION OF POTENTIAL NON ROUTINE DISCHARGES 9 2.1 General Assessment of Presented Data 9 2.2 Construction Phase Discharges 9

2.2.1 Onshore Facilities Construction 10 2.2.2 Jetty Infrastructure Construction 11 2.2.3 Potential Spills from Support Vessels 12 2.2.4 Information Gaps: Non Routine Construction Phase Discharges 12

2.3 Operational Phase Non Routine Discharges 12 2.3.1 Discharges Associated with Fire Events 13 2.3.2 Fuel Oil Spills 14 2.3.2.1 Character of Fuel Oils 14 2.3.2.2 Potential Volumes of Fuel Spills 16 2.3.3 Spills of Other Materials 22 2.3.3.1 Lubricating Oils 22 2.3.3.2 Hydraulic Fluids 23 2.3.3.3 Chemicals 24

3.0 ASSESSMENT OF THE DISTRIBUTION AND PERSISTENCE OF

NON ROUTINE DISCHARGES 25 3.1 Overview 25 3.2 Fire Foam and Fire Related Discharges 25 3.3 Oil Spills 25 4.0 IDENTIFICATION OF RECEPTORS, (RESOURCES LIKELY TO

BE IMPACTED) 29 4.1 Overview 29 4.2 Non Routines Discharge Receptors 29 5.0 ASSESSMENT OF POTENTIAL ENVIRONMENTAL EFFECTS 31 5.1 Overview 31 5.2 Assessment of Construction Phase Non Routine Discharges 31 5.3 Non Routine Operations Phase Discharges 31

5.3.1 Fuel Oil Spills 31 5.3.2 Lubrication Oils 33 5.3.3 Hydraulic Fluid 34

5.4 Potential Long Term Effects 34 5.5 Cumulative Effects 35 5.6 Presentation of Assessment Data 35


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6.0 PROPOSED MANAGEMENT STRATEGIES FOR NON ROUTINE

DISCHARGES 36 6.1 Overview 36 6.2 Construction Phase 36 6.3 management of Operations Phase Non Routine Discharges 38 7.0 SUMMARY AND CONCLUSIONS 41 7.1 Construction Phase Non-Routine Discharges 41 7.2 Operations Phase Non Routine Discharges 42 7.3 General Comments on Presentation of Information in the EES 44 8.0 REFERENCES 46 9. STATUTORY DECLARATION 48 ATTACHMENT A: THE USE OF TOXICITY DATAIN OIL SPILL

EFFECTS STUDIES 49 ATTACHMENT B AUTHOR’S CV (SUMMARY) 52 ATTACHMENT C: OCCASIONAL DISCHARGES 60 ATTACHMENT D: LETTER OF BRIEF 63


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1.0 INTRODUCTION 1.1 Purpose of this Report 1.1.1 This Report reviews part of the Environmental Effects Statement (EES) for the

Gas Import jetty and Pipeline Project (the Project) proposed by AGL (the Proponent) for Crib Point in Westernport Bay (WPB), Victoria, Australia.

1.1.2 The Report reviews and discusses the information presented in the EES

regarding the planned (routine) discharges of materials into Westernport Bay and also potential non-routine discharges (spills or other releases), their effects on the receiving environment (as outlined in the EES) and the mitigation and management procedures proposed by the project Proponents.

1.2 Rationale and Methodology 1.2.1 For a systematic and transparent assessment of the effects of discharges to the

marine environment, it is considered that the AGL EES should proceed through five key steps or tasks:

1. Identification of materials that will be, or could potentially be, discharged to the

marine environment. This includes: Routine discharges, i.e. those materials at are planned to be discharges either

continuously or regularly. Non routine discharges; i.e. those in response to infrequent or unplanned

events. This task should also identify volumes and locations of releases. The adequacy of the EES’ completion of this task is discussed in Section 2.0 of this Report.

2. Assessment of the likely distribution of these discharges. This should include modelling of spatial distribution (surface and subsurface trajectory modelling) and temporal distribution (persistence; fate and dilution, if applicable). This task should consider potential flushing from Westernport bay waters and also the potential breakdown products (Section 3.0).

3. Identification of likely “receptors”, i.e. those components of the environment most likely to be impacted by (i.e. exposed to) each contaminant or associated breakdown products and those likely to be most adversely affected. Seasonal variations would need to be considered. Receptors should be identified within the entire area impacted by the discharged materials, including any areas outside of Westernport Bay (ref. point 2 above) ( Section 4.0).

4. Assessment of potential environmental effects. This must be based on an assessment of environmental conditions within the Bay and the vulnerabilities and sensitivities of the resources at risk from each discharge. It should also include assessments of short and long term effects, sublethal and lethal effects, the significance of these and anticipated recovery rates (for non routine events). Post Project or post spill rehabilitation should also be discussed. The effects of breakdown products should also be considered. Assessments of spill events should include an assessment of the effectiveness response actions and consider a non-effective (or no) response scenarios (Section 5.0). In order for this to be done, details of planned response actions must be set out (see below).


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5. Development of management strategies to reduce or eliminate these effects.

The EES should detail the basis for the design of strategies and also set out management protocols to ensure their effective implementation and ongoing management. For routine discharges this should include discharge minimisation ongoing monitoring and effects mitigation. For non routine (accidental) discharges this should also include containment and cleanup methods and priorities, post spill monitoring and restoration. This is discussed in Section 6.0.

1.2.2 Each of these will be assessed in this review (see Section 1.3 below).

1.2.3 The review will also comment on the structure and integrity of the EES itself,

primarily: 1. Quality of presented data:

Adequacy: Is information sufficient to allow an analysis of environmental effects?

Clarity and consistency: Is the data presented always the same throughout the documents?

Accuracy of data: Is the data correct and complete? Relevance: Is the information linked to the issue being discussed?

2. Utility of the EES and associated documents: Clarity: Is information presented clearly, simply and consistently so as

to allow the public and other reviewers to assess the contents? Focus: Is the EES concise; free of repetition and/or irrelevant

information? Accessibility: Does the EES use summaries and Tables to allow

rapid and clear access to the presented information? 1.2.4 Note: Only issues related to marine discharges are addressed in this report. 1.3 Report Structure 1.3.1 This Report comprises 8 Sections:

An Introduction (this Section) which sets out review and report

development methods. Five Core Sections reviewing the key steps outlined in Section 1.2. Summary and conclusions. References for documents cited in the Report.

1.3.2 Additional attachments are provided as needed. 1.3.3 Each of the five Core Sections will comprise the following components:

Summaries of EES findings. Assessment of presented data and methods. References to third party materials where pertinent and available. Discussion and conclusions.


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1.3.4 Wherever required the relevant AGL documents, or parts of documents, are

cited in the text. 1.3.5 For clarity, these key points may be presented in text ‘boxes’. 1.4 Statement Limitations 1.4.1 Limited time has been available for the review of the EES document which

comprises over 11,000 pages: 27 chapters (main document), 19 Technical Reports and associated ‘Annexures’ (47 files) and 9 Attachments (12 files) and associated Appendices.

1.4.2 This review has therefore been based on a review of only those parts of the

EES that appear to be relevant to marine discharges (see Report Section 2.1). 1.4.3 A key word search was undertaken of other documents presented to reduce the

risk that pertinent information and data was missed. 1.4.4 Review of the main EES Chapters has been further impaired by the total

absence of cross referencing in the EES to relevant sections of the more detailed Technical Reports and Attachments. This makes location of the justification of environmental effects assessments (if presented) difficult.

1.4.5 Repetition of information presented through the documents is substantial,

adding considerably to the bulk of the EES. Chapter 6, in particular, unnecessarily repeats large tracts of text describing the existing Westernport Bay environment that are directly lifted from Technical Report A. Simple references to Technical Report A would have substantially reduced the size of Chapter 6 and facilitated the transfer of information.

1.4.6 The EES would have been better served had the main document interpreted

and used the data presented in the Technical Appendices rather than simply repeating it. This relates particularly to the ecological data and Technical Appendix C.

1.4.7 Much of the information in Technical Appendix C is well presented but does not

seem to have been applied to any of the effects analysis or assessments. 1.4.8 A number of inconsistencies were noted in the repeated information. This

includes differences in quantitative data (e.g. discharge volumes) and variation in procedures.

1.4.9 There are numerous data gaps in the main document and only a few of these

can be filled with reference to the Technical Appendices and Attachments. 1.4.10 These are noted in this Report.


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1.5 Key EES Documents and Sections Reviewed 1.5.1 The following parts of the EES were reviewed: EES Volume 1 Chapter 3 Project Development; in particular Section 3.2

Gas Import Jetty Works Design Development which dels with environmental considerations in FSRU design. This is detailed in Technical Report A (see below).

EES Volume 1 Chapter 4 Project Description. This section summarises design, construction and operation of the Project. In particular, Section 4.3 Gas Import Jetty Works which describes Floating Storage and Regasification Unit (FSRU, Section 4.3.1), and . Section 4.8 Waste and Spoil Management which deals mostly with wastes associated with onshore construction and operations.

EES Volume 2 Chapter 6 Marine Biodiversity. This is a summary ( 124 pages) of Technical Report A (508 pages, see below). Little additional analysis or explanation is provided in this Chapter.

EES Volume 2 Chapter 16 Safety Hazard and Risk. This Chapter addresses health and safety risks (public and workforce). Only Section 16.7 “Emergency Management and Response” is relevant to an assessment of effects on the physical or natural environment and an assessment of remedial strategies.

EES Volume 3 Chapter 25 Environmental Management. In particular, Table 25-4 Summary of Mitigation Measures (pages 25-31 to 25-36; MM-ME01 to MM-ME16) Note this table should be viewed along with Table 6-11.

EES Volume 3: Chapter 16 Conclusions. Technical Report A Marine Biodiversity. This TR was prepared by CEE Pty

Ltd (full title: “Marine Biodiversity and Impact Assessment”). The TR describes the WPB marine environment (Section 5), based on a desktop review (see Section 4.1) and some field surveys (see Sections 4.2 and 4.3).

Technical Report C Surface Water Impact Assessment. This considers potential discharges to land and other works that could produce discharges such as erosion runoff. Potential impacts to marine waters are deferred to Technical Report A.

Technical Report K Safety Hazard and Risk. This TR deals mostly with LNG releases and fires. Spills of hazardous materials (including oil) to the waters of WPB are mentioned only in respect to a need for this to be addressed in future Emergency Response Plans.

Attachment III Environmental Risk Report, in particular Appendix B; Risk Register.


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2.0 IDENTIFICATION OF POTENTIAL NON ROUTINE DISCHARGES 2.1 General Assessment of Presented Data 2.1.1 Risks to the marine environment are introduced in Section 6 of the EES and a

summary table is presented; Table 6-11 (EES Section 6.4). 2.1.2 Unfortunately, this table is indicative of a consistent flaw in the EES; it provides

superficial information with no referencing of those sections of the EES where details or explanations can be found.

2.1.3 The EES does not contain a summary table showing all of the planned or

potential discharges noted in text of the supplied documents. As noted in Section 1.4 this, together with the absence of cross referencing (see Section 1.4), makes it difficult to systematically identify and quantify discharges to the marine environment.

2.1.4 The EES does contain a number of repetitive tables which list routine (planned)

discharges and some potential non-routine (accidental) discharges. As noted in subsequent sections of this Report , information is not always consistent.

2.1.5 Table 1 of this Report summarises listed potential discharges for the

construction phase of the Project. Most are referenced in the EES but not all are assessed in any way.

2.1.6 Table 2 summarises those potential discharges identified for the operational

phase of the Project. 2.1.7 Tables 1 and 2 both reference where in the EES information regarding

discharges is mentioned and also indicates, where appropriate, some inconsistencies and inadequacies in the supplied data.

2.2 Construction Phase Discharges 2.2.1 The EES does not provide much information on potential discharges (neither

routine nor non-routine) to the marine environment during the construction phase of the project.

2.2.2 Table 6-11 (EES Section 6-4) presents only one construction –related risk

(ME41): 2.2.3 “ Hazardous material or waste spill/leaks

Accidental spills or leaks from chemicals or waste streams into Western Port during construction ” (EES Table 6-11 ME41)

2.2.4 The chemicals and waste streams are not identified in Table 6-11 nor in EES

Section 6.5 which deals with construction phase discharges.


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2.2.5 EES Section 6.5 does however offer a more detailed interpretation of ME41: 2.2.6 “ Construction of the Gas Import Jetty Works may result in a risk of spills and

leaks of fuels and chemicals, particularly during construction of gas piping on the Crib Point Jetty and installation of the marine loading arms (Risk ID ME41).

2.2.7 The EES needs to provide details of the products that may be spilled in the sea

during construction. 2.2.8 The potential for spills from hydraulic hoses or diesel fuel is noted in EES EES

Section 6.1 but is not addressed or even referred to in EES Section 6.5. 2.2.9 The EES lacks detail on what the identified spill products actually are. For

example, the type of hydraulic fluid and grade of diesel is not mentioned although the latter is assumed to be automotive and locally sourced.

2.2.10 Numerous types of lubricating oil are possible and identification of these is

important in determining the behaviour and effects of these if spilt into the marine environment.

2.2.11 The EES should stipulate the type of lubricating oils used during construction,

particularly if stored, transported or transferred on the jetty. 2.2.12 The potential for construction stage spills or discharges from the FSRU is

unclear as contradictory statements are made within this single EES Section: 2.2.13 “ The FSRU would be brought to Western Port ready to operate at the existing

Crib Point Jetty (Berth 2) with proposed modifications implemented. This means that no construction impacts would be associated with locating the

FSRU at the Crib Point Jetty. ” (EES Section 6.5). 2.2.14 “ There would be some installation work once the FSRU is berthed prior to

start-up. This would include mounting the seawater intakes to the hull of the FSRU and fastening the marine loading arm connection.” (EES Section 6.5.1).

2.2.15 Table 1 lists potential discharges that are considered by this author to be

potential discharges based on the description of construction activities on the onshore worksite and on the jetty that are provided in the EES.

2.2.1 Onshore Facilities Construction 2.2.1.1 Attachment III, Appendix B and Technical Report C identify a number of

potential discharges to land that could impact on the marine environment via freshwater creeks and channels:

Dewatering operations.

Stormwater runoff. Runoff from disturbed areas such as drilling sites and pipeline water. Spills of hazardous materials (including fuel) to water courses .


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2.2.1.2 A number of strategies are noted to manage dewatering operations and

stormwater and other runoff. 2.2.1.3 Oil or chemical spill risks are generally assessed as low on the basis of low

volumes of either stored, location of storage tanks and refuelling areas away from water courses and use of bunding etc.

2.2.1.4 There seems to be no discussion of the effectiveness of bunding during high

rainfall and no details of oil and chemicals stored on the worksite (type, volumes and storage systems) are provided.

2.2.1.5 Potential contamination of stormwater runoff is not discussed. 2.2.1.6 The EES does not provide a list of hazardous materials to be used or stored on

the various work sites. This needs to be provided, together with volumes of on site storage, if a general assessment of spill risk is to be undertaken.

2.2.1.7 A construction site map showing location of hazardous materials storage,

coupled with the site drainage map and location of surface water bodies s also needed if risks of spills entering the bay via creeks and drains are to be quantified.

2.2.2 Jetty Infrastructure Construction 2.2.2.1 Jetty infrastructure to be constructed on the Crib Point Jetty, includes marine

loading arms (MLAs), gas pipeline, electrical and instrumentation equipment and a fire-fighting system.

2.2.2.2 Little detail of potential discharges arising from the construction of the jetty

infrastructure is provided. Section 4.8.1 notes three potential contamination sources (see Table 1) but is it is not clear whether pipeline related discharges apply to the jetty section of the pipeline.

2.2.2.3 Similarly, it is unclear whether hydro testing of jetty pipelines will be undertaken

and, if so, how water will be managed. 2.2.2.4 Spills of oil and chemicals are again noted as possible in Section 6 of the EES

and in Technical Report A: 2.2.2.5 “ Construction of the Gas Import Jetty Works may result in a risk of spills and

leaks of fuels and chemicals, particularly during construction of gas piping on the Crib Point Jetty and installation of the marine loading arms “(EES Section

6.5) 2.2.2.6 Again, no information regarding fuels or chemicals to be used or stored on the

jetty is provided.


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2.2.3 Potential Spills from Support Vessels 2.2.3.1 The EES provides no information regarding the use of support vessels for jetty

works or the use of supply vessels to support jetty of onshore activities. 2.2.3.2 Presumably, the FSRU will be moved onto the jetty berth using tugs but no

information regarding the number or configuration of these is provided. 2.2.3.3 The EES should provide details of support vessel movements associated with

construction activities so that spill risks can be determined. 2.2.4 Information Gaps: Non Routines Construction Phase Discharges 2.2.4.1 The EES needs to provide more information to allow for the accurate

identification of potential discharges to the marine environment during the construction phase and to quantify the character of these discharges (key components, volumes, temperatures, concentrations).

2.2.4.2 The following information is required in order to assess spill related risks: 1. Calculation of risks of turbid water overflow due to storm conditions of

bunding failure: Estimates of potential water volumes arising from dewatering

operations. Estimates of potential stormwater runoff, together with; Anticipated seasonal (or monthly) volumes and

2. Assessment of chemical spill risks: Details of on site holding capacity and consequent potential offsite run-off. List of hazardous materials to be used or stored on all work sites,

together with volumes of on site storage Details of on site storage of oil and chemicals as opposed to

statements to the effect that these are outlined in other documents. Construction site map showing location of hazardous materials storage,

activities producing run-off and showing location of creeks and inlets to water courses.

3. Assessment of vessel based spill risks: Details of support vessels used at jetty of elsewhere and support vessel

operations. This should include fuel and cargo volumes in order to quantify spill risks.

Details of support vessels use during construction. 2.3 Operational Phase Non Routine Discharges 2.3.1 Table 2 provides a list of potential non-routine discharges to the marine

environment that may occur during the operational phase of the project, as listed in the EES.


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Table 1 List of Non Routine Discharges During the Construction Phase of the Project

Ref Discharged Material Hazard Potential Volume

Release Point/Source EES Reference

1.1 Chemical or oil spills from jetty 2

Oil or chemical pollution

Not stated Jetty or FSRU Via creeks and channels

Att III App B Section 6-5 and Att. III (Risk ID ME41), Section 6.6.5

1.2 Oil spills from land Oil or chemical pollution

Not stated Via creeks and channels

TR C (HD5, HD8), Att III (Risk ID C11), TR C Section 7.1.3

1.3 Oil spills from vessels 2 Oil pollution Not stated Vessel (jetty or other) Not noted 2.4 Run-off Turbidity Not sated Jetty


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Table 2 List of Routine and Non Routine Discharges During the Operational Phase of the Project

Ref Discharged Material Hazard Potential Volume Release

Point/Source EES Reference

2.1 Water curtain: During fire emergency

Contaminated seawater

5,760 m3/day 6,900 m3 over 6 hrs

Jetty S6.1.1, Table 4-3, 6-1 TR K pp47-48

2.2 Fire fighting foam possibly with seawater

Fire fighting foam

Not calculated Jetty Section 4.3.1

2.3 Fuel spill (FSRU) Marine diesel 5,600 m3 storage capacity

FSRU at berth or in transit (Maintenance)

Table 4-2

2.4 Fuel spill (LNG Tankers)

Marine diesel 30m3 considered 7 Various Technical Report A pp399

2.5 Fuel spill (tug) Marine diesel Not addressed Various Not addressed 2.6 Lubricating oil

(FSRU) Lubricating oil 220 m3 storage

capacity FSRU at berth Table 4-2

2.7 Chemical spills Chemical pollution

Chemicals and volumes not noted

Jetty, vessels or FSRU

Technical Report A pp 398 (but not addressed)

2.8 Oily sludge spills Oil pollution 25t/month produced but storage capacity

not stated

FSRU at berth Chapter 6 pp6-110 Tech Report A pp 398

2.9 Hydraulic fluid Chemical (oil?) pollution

Not stated FSRU and jetty Technical Report A pp398

2.10 Land spills of oil or chemicals entering bay via waterways

Oil or chemical pollution

Not quantifies Chemicals or oil not

identified

Freshwater creels, drains or inlets

Technical Report C (Risk ID HD8)

2.11 Grey/ black/ bilge waste waters (sewage and bilge water)

Oil and other contamination

Not defined Risk of spills not

addressed

FSRU or other vessels

Section 4.8


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2.3.2 Potential non routines (or emergency) discharges can be divided into four groups, spills arising from:

1. Fires and fire-fighting. These could comprise; Seawater from the firewall. This will likely contain combustion products

or other contaminants. Fire-fighting foam

2. Fuel oil spills (diesel)from a number of possible sources.3. Spills of lubricating oils.4. Chemical spills.

2.3.1 Discharges Associated with Fire Events

2.3.1.1 The EES states in numerous places that the use of fire-fighting foam will be used. No details of the type to be used, volumes stored or expected to be used in various scenarios makes it impossible to assess the effectiveness of firewater and foam run-off or the potential effects of these on the marine environment.

2.3.1.2 “ Foam use on the jetty would be minimised as far as practicable in order to avoid environmental spill of fire fighting foam. ” (EES Section 16.6.1,

Technical Report K pgs 47-48).

2.3.1.3 Again, it is difficult to determine whether the use of foam will be minimal since application rates and emergency procedures are not provided.

2.3.1.4 “ Portable foam carts (100-200L capacity), capable of extinguishing the largest identified hydrocarbon pool fires on Berth 2 ” (EES Technical Report

K pp 46).

2.3.1.5 It is not reported how many portable foam carts will be available, nor is it stated anywhere that a fixed fire-foam tank will be part of the fire-fighting system. Indeed:

2.3.1.6 “ The size and quantity of these extinguishers will be determined in Detailed Design. ” (EES Technical Report K: Pages 47-48).

2.3.1.7 Consequently, it is not possible to calculate the volumes of foam that could be spilled, or used during a range of fire scenarios.

2.3.1.8 “ All deck areas of Berth 2 have bunding/ kerbing to contain spills and fire fighting consumables to an extent that is practicable. ” (EES Section 16.6.1,

Technical Report K pgs 47-48)

2.3.1.9 It is unlikely that the onboard (or on jetty) bunding will be sufficient to contain the 6,900m3 (6.9 megalitres) of seawater applied over a six hour period from the deluge system.


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2.3.1.10 Combustion of methane produces CO2 and water and so contamination from

gas combustion is unlikely. However, potential combustion by-products from burning infrastructure is not noted or considered.

2.3.1.11 Potential volumes of fire foam that could be released during a fire response

are not calculated and so potential effects cannot be calculated. 2.3.1.12 The EES should calculate potential losses of fire foam to Westernport bay

waters during fire events and present an assessment of potential effects. 2.3.1.13 No information about the type of foam to be used is supplied. This is critical

given the toxicities (both short and long term) of some products. 2.3.1.14 The EES must provide details of fire foam to be used, including toxicity and

fate and effects in the marine environment so that potential effects can be identified and calculated.

2.3.2 Fuel Oil Spills 2.3.2.1 Character of Fuel Oils 2.3.2.1.1 The fuel oils to be used by the FSRU, tugs and LNG tankers are referred to in

the EES as ‘diesel’, ‘marine diesel fuel’ (MDF), ‘marine diesel’ or ‘’marine diesel oil’ (MDO). The term is sometimes also used to refer to marine gas oil (MGO).

2.3.2.1.2 Marine diesel oils vary widely in their physical and chemical character and

these differences are important in assessing potential toxicities and also spill fates and trajectories. These differences and their implications for any environmental assessment are summarised in Table 3.

2.3.2.1.3 The EES does not detail the specifications of the marine diesel fuels to be

used in the FSRU or tugs and this significantly compromises the assessment of oil spill effects (see Section 5).

2.3.2.1.4 Fuel for the tugs to be used at Crib Point are almost certainly going to be

locally sourced and so the specifications of this fuel could easily be obtained by obtaining SDS (MSDS) from local operators or suppliers and then requesting analytical data from the manufacturer.

2.3.2.15 It is unclear whether diesel fuel on the FRSU will require the same

specification (and therefore also be locally sourced) but the Proponents must be able to report on this.

2.3.2.1.6 It is unclear whether the FSRU will come to Crib Pont during the construction

stage will be loaded with fuel oil; i.e. will it come in under tow or under its own power ? The character (specifications) of the diesel onboard the FSRU (or trugs) when it first comes to Crib Point should be noted.


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Table 3 Range of Specifications for Marine Diesel Oils (MDO) and Marine Gasoil

(MGO) and Significance for Assessment of Spill Behaviour and Effects

Range Characteristic of MDO/MGO MDO MGO

Relevance to Effects Assessment

Specific Gravity (Density) @15oC

0.82 to 0.9

Up to 0.89

Indicative of the proportion of light (volatile) and heavier (persistent) components. Important for fate and trajectory modelling.

Viscosity (cSt @ 40oC 1

8 – 12 (2-11)

5 – 6 (< 11)

Influences spreading rates and amenability to some cleanup methods.

Pour point Variable -15 to 12

-6 to 0(<6)

Important only for oils wit pour points close to ambient temperatures.

Spreading Coefficient

High to very high

High Important for determining the ‘footprint’ of surface oil and influences evaporation rates and slick ‘break-up’.

Aromatics 2, 3 Highly variable. Usually ~30% but may be up to 60%.

Toxic components of oil determine effects on impacted biota. Lighter aromatics may be soluble and effects on biota in the water column.

Volatile components 3

Low Low

These should evaporate quickly reducing persistence of spilt oil on the water surface. Important for plotting oil spill persistence and hence longer term trajectories. May persist in sediments.

Water soluble fraction (WSF) 4

Very Low (Not soluble)

Indicates the likelihood soluble components entering the water column and hence potential effects on subsurface marine organisms. Rate of dissolution is aided by wave action and mixing energy generally. Important for spill trajectory modelling output.

Water miscible fraction (WMF) 4

Very Low (Not miscible)

Indicates the likelihood of oil droplets becoming suspended (entrained) in the water column and hence affecting subsurface marine organisms. Rate of entrainment is aided by wave action and mixing energy generally. Important for (2D and 3D) spill trajectory modelling output.

Asphaltenes

Low to moderate

Very Low

Large (heavy) hydrocarbons; these compounds do not evaporate or degrade. High asphaltene oils tend to leave a residue, although this may be physically removed. Influences trajectory modelling output. High asphaltene oils also tend to form stable oil in water emulsions.

Distillation fractions5

Highly variable This data is critical for predication/modelling of oil persistence on the water surface.

1 Viscosities are variably reported for different temperatures. Viscosities at ambient Westernport bay seawater temperatures can be easily calculated. This does not seem to have been done. 2. Also indicated by a ‘Calculated Carbon Aromaticity Index (CCAI). 3 Note: Not usually recorded on SDS/MDS but important considerations in assessing likely harm to biota (either through direct impact or presence in the water column). 4 See Attachment A. 5 This is critical information if accurate (as opposed to indicative) weathering (persistence) is to be modelled.


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2.3.2.1.7 No information is supplied with regards the likely, or possible,

characteristics of diesel fuel oils on LNG tankers. If the source of these tankers or fuels (i.e. bunkering locations) is known then characteristics may be identified or deduced. This information would identify the range of fuels that could be in Westernport Bay and allow the selection of indicative (typical) or worst case spill scenarios.

2.3.2.1.8 The information provided in the EES regarding the character of fuel oils

does not allow an adequate assessment of spill fates or effects. 2.3.2.2 Potential Volumes of Fuel Spills 2.3.2.2.1 No quantitative calculation of potential fuel oil spill volumes has been

undertaken for the EES. 2.3.2.2.2 The EES provides qualitative assessments and generally dismisses the

likelihood of any but small spills occurring: 2.3.2.2.3 “ Most oil spills from marine vessels result from accidents in re-fuelling. The

FSRU would mostly be powered by LNG and, as such, there is not sufficient oil on board to cause a moderate to large oil spill and so is not subject to this

risk. “ (EES Section 6.5.5 pp 6-110). 2.3.2.2.4 The EES also states that fuel volume on board the FSRU is 5,600 m3. This

is more than enough to cause a major oil spill. 2.3.2.2.5 Presumably LNG tankers will carry similar volumes since the EES states

that LNG tankers and the FSRU have similar designs (EES Section 6). 2.3.2.2.6 Fuel Spills from the FSRU 2.3.2.2.7 Risks of spills from the FSRU are not quantified and potential spill scenarios

are not explored: 2.3.2.2.8 “ Only minor quantities of fuels and chemicals would be stored and used on

the FSRU, in containers within bunded storages. ” Technical Appendix A page 399.

2.3.2.2.9 “ For a significant loss of diesel or fuel oil to occur, the outer and inner hull

of the vessel would have to be breached at the point where a storage tank is located on the vessel. In the unlikely event of this happening, there are also multiple bunker tanks meaning that fuel can be transferred to intact tanks

and it would be improbable that a large complement of diesel fuel would be lost. Overall, the potential for a large spill of diesel is considered to be very

unlikely. ” (EES Section 6.5.5). 2.3.2.2.10 The EES provides no FSRU design so the existence of a double hull over

fuel tanks cannot be verified. Although it is agreed that modern LNG carriers are so deigned (and some are fuelled entirely by LNG),


19

2.3.2.2.11 The EES should provide the FSRU design in order to substantiate these

statements in the EES. A diagram clearly showing the position of the diesel tank(s), elevation, hull configuration and details of vessel (LNG tanker and tugs) movements during construction and operations would assist in the assessment of spill risks.

2.3.2.2.12 Fuel Oil Spills from LNG Tankers 2.3.2.2.13 A ‘credible spill volume has been identified for LNG tankers for the purposes

of assessing (unspecified) consequences: 2.3.2.2.14 “ An assessment of consequences has been made for a credible spill of 30

tonnes of diesel over a period of three hours from a breached diesel storage tank on an LNG carrier near McHaffie’s Reef in the extremely unlikely event of a spill of this size occurring. This corresponds to rupture at the centre of a partly full tank with crew response in an hour and corresponds to the 90 per cent spill recorded in similar situations from similar vessels. It is considered the credible diesel spill event from an LNG carrier normally using LNG as

fuel. ” (EES S6.5.5 pp 6-111). 2.3.2.2.15 No justification for the 30m3 volume is provided. 2.3.2.2.16 It is unclear why a point near McHaffies Reef was chosen; perhaps the

scenario is a grounding (see Section 3.2). 2.3.2.2.17 Without any information on diesel fuel tank configurations, the significance

and meaning of “the centre of a partly full fuel tank” is unclear. 2.3.2.2.18 It is also unclear why a diesel tank would be assumed to be only partly full.

An LNG tanker coming into Crib Point would presumably be coming in after travelling on LNG. Why is it not assumed that the tanks would be full? It would leave after offloading LNG but would not have consumed a significant of diesel while at berth.

2.3.2.2.19 For the purposes of modelling spill volumes and trajectories, diesel fuel

tanks should be assumed to be full. 2.3.2.2.20 The meaning of “90 per cent spill recorded in similar situations from similar

vessels” is also unclear. If data relating to LNG diesel fuel spills was provided then this may make sense.

2.3.2.2.21 The possible responses of the LNG crew are not set out but may include

transfer of fuel to undamaged tanks. In the absence of any details regarding the possible scenarios considered in the EES no assessment can be made of possible crew actions.

2.3.2.2.22 No evidence has been presented to suggest that pumping from a breached

fuel tank into other tanks is possible or feasible. The statement relies on the assumption that “multiple bunker tanks” have spare capacity.


20

2.3.2.2.23 Reaction times (including time taken to detect a breach and loss of fuel and

integrity of other tanks), pumping rates and probability of spare capacity would need to be used to calculate potential (worst case) releases in such a scenario.

2.3.2.2.24 The presence of multiple bunker tanks is mentioned only in Technical

Report A, Section 7.9.2 9 (and the identical paragraph in Section 6.6.5). 2.3.2.2.25 The EES does not contain any shipping risk assessment. Such risk

assessment should identify other hard grounding sites (The Nobbies, Tortoise Head) and potential soft grounding sites and possible high risk areas or operations for vessel-vessel conditions. This would provide some basis for calculation of potential spill volumes, trajectory modelling and a valid assessment of environmental risks.

2.3.2.2.26 “ The small volumes of diesel fuel onboard the FSRU and visiting LNG

carriers, combined with the mitigations of fuel being stored in multiple smaller tanks and the fact that LNG vessels are double hulled means the

likelihood of a major spill is considered highly unlikely. ” (EES Section 6.5.5 pp 6-110).

2.3.2.2.27 The EES repeatedly states that spill volumes will be small but other reports

are not so dismissive of potential spill volumes: 2.3.2.2.28 “… if a tanker were to drift onto the windward shores of the approach to Port

Phillip Bay and Westernport significant wave action is likely to lead to complete loss of the vessel and her cargo.” (Victorian Maritime

Emergencies (NSR) State Emergency Response Subplan page 16). 2.3.2.2.29 “ The strong tides and shallow waters of Western Port render this

environment vulnerable to large oil spills (Toll Western Port 2001). Vulnerable resources include aquaculture facilities, penguin rookeries

(particularly on Phillip Island), mangrove swamps and recreational beaches (Toll Western Port 2001).

2.3.2.2.30 This observation applies equally to LNG tankers. 2.3.2.2.31 The potential spill volumes provided in the EES do not relate to the

proposed Project and do not allow an adequate assessment of spill trajectories, fates or effects.

2.3.2.2.32 The EES does not consider spills resulting from collisions with third party

vessels. These include (see Table 4): 2.3.2.2.33 FSRU-tug.

FSRU-LNG tanker. LNG tanker-tug. Tug-tug. Tug-third party vessels including oil tankers and cargo vessels.


21

Table 4 Data Requirements for an Assessment of Potential Fuel Spill Volumes

Potential Spill Scenario Information Requirements to calculate

Volumes EES

ReferenceFuel tank locations for each tug or ‘worst case’ tug.

None

Volumes of oil in each tank. None Tank configuration (are any adjacent). None

Tug - Tug

Hull configuration (single or double). None

As above for tug. None Location of fuel storage tanks on FSRU. None Configuration of tanks. None

Volume of each tank. See Note 1

Tug - LNG tanker

FSRU hull configuration, generally and over the fuel tanks.

None

Details of FSRU as above. None Location of fuel storage tanks on typical LNG tanker.

None

Configuration of tanker tanks (typical). None Volume of each tank (typical). None Typical tanker hull configuration. None

LNG tanker - FSRU

Location of fuel storage tanks on FSRU. None Details of FSRU as above. None

Ship-Ship Collision

FSRU - Tug Details of tug as above. None

Tug As ter Tug-tug collision scenario. None LNG tanker As per LNG-FSRU scenario above. None FSRU AS per scenarios above. None

Grounding

Generally Potential grounding sites/ spill scenarios. See Note 2 Flow rates for operation. None FSRU Spill control protocols. See Note 3 Flow rates for operation. None

Loading Operations

Tug Spill control protocols. See Note 4

1 Total diesel volume is noted but it is not stated whether this is in one or multiple tanks 2 EES Section (Technical Report A Section 7) cites McHaffie Reef as a potential site. It is unclear why this site was identified but is possible that this choice is based on scenarios considered by AP-ASA (2013), a study based on oil tanker movements and undertaken for the Victorian National Parks Association(VNPA 2014a, 2014b, 2014c). The APASA report did not consider the AGL Project nor did it report did not include any identification of all possible grounding sites or even an identification of worst case. 3 See Section 6. 4 EES Section 6.5.5 (pp 6-110) outlines refuelling spills protocols. But presents no calculation nor consideration of protocol failure (alarms, shutdown containment etc.).

2.3.2.2.34 Some information on LNG tanker design is provided: 2.3.2.2.35 “ LNG carriers are vessels of a similar size and design as the FSRU. ”

(EES Section 4.3).


22

2.3.2.2.36 This information is not helpful since, as noted previously, no FSRU design

is provided. 2.3.2.2.37 Potential spill volumes have not been calculated with reference to credible

or worst case scenarios. Indeed few scenarios are considered at all. Consequently the risk assessments relating to oil spills are inadequate.

2.3.2.2.38 Anecdotal information is provided in the EES to justify consideration only

of small diesel spill volumes: 2.3.2.2.39 “ Small diesel spills typically involve the release of three to 30 litres of

diesel. No diesel spill has exceeded three litres at the Port of Hastings in recent years (pers comms Strategy Manager, PoHDA, May 2020).” (EES

Section 6.6.5 Page 6-108). 2.3.2.2.40 “ Over the last three years, there have been an average of 2.5 notified

spills per year at the Port of Hastings, all involving small quantities (less than five litres) of diesel or unleaded petrol (mostly from containers knocked over). ” (EES Section 6.6.5 Page 6-107).

2.3.2.2.41 Inasmuch as all spills within the Port are recorded, a more quantitative

and reliable estimate of past could have been obtained. It would have also provided more accurate information regarding the causes and source of diesel spills (see Figure 1).

2.3.2.2.42 This data should be obtained from more than three years records. 2.3.2.2.43 If the past spill record of marine operations in Westernport are to be used,

then the EES should present an accurate record of spills (oil types, volumes and sources) based on the readily available spill records for marine and port activities in Westernport Bay.

2.3.3 Spills of Other Materials 2.3.3.1 A number of other potential spill sources are noted throughout the EES

although details are lacking and most have been given little if any consideration in the overall environmental risk assessment (Technical Report A, Section 7).

2.3.3.1 Lubricating Oils 2.3.3.1.2 The storage and use of lubricating oil (presumably diesel engine oil) is

noted in the EES (see Tables 1 and 2). 2.3.3.1.2 No calculations of the potential volumes of these that can be spilled are

provided and no information about storage tank capacities or location of storage tanks is provided.


23

2.3.3.1.3 Information regarding the storage, handling and potential size of spills of

lubricating oils is inadequate to assess the potential effects of these.

Figure 1 Documented Oil Spills in Westernport Bay 1999-2007 (From Melbourne Water and Port Phillip and Westernport CMA, 2020)

2.3.3.1.4 No details are provided regarding the type or character of the intended

lubricating oil. 2.3.3.1.5 Information regarding the character of lubricating oils is inadequate to allow

any assessment of fates or effects of any potential effects of these. 2.3.3.2 Hydraulic Fluids 2.3.3.2.1 The use and transport (re-supply) of hydraulic fluid is noted in the EES (see

Tables 1 and 2). 2.3.3.2.2 It is not stated whether these are oil-based (and hence insoluble) or glycol

based (and usually soluble or water miscible). This is important in determining fates, vertical distribution in the water column and trajectories of any spills of these.

2.3.3.2.3 No calculations of the potential volumes of hydraulic fluids that can be

spilled are provided and no information about storage tank capacities or location is provided.

2.3.3.2.4 Volumes of used lubricating fluid stored and transported should also be

considered in the EES as these can contain significant levels of PAHs (Wang et al 1999).


24

2.3.3.2.4 Information provided in the EES regarding the type, storage, handling and

potential size of spills of hydraulic fluid is inadequate to assess the potential effects of these.

2.3.3.3 Chemicals 2.3.3.3.1 No information relating to solid or liquid chemicals stored or used is

provided in the EES. 2.3.3.3.2 The EES should include a full inventory of chemicals used and stored at the

proposed facility and clearly identify those that could, under any scenario, bee spilled into Westernport Bay.


25

3.0 ASSESSMENT OF THE DISTRIBUTION AND PERSISTENCE OF NON ROUTINE DISCHARGES 3.1 Overview 3.1.1 Identification of the likely distribution (spatial and temporal) of materials

discharged or spilled to the marine environment is essential in assessing the potential scale of any adverse effects.

3.1.2 This is done in the EES using either qualitatively or quantitatively methods, or

both. 3.1.3 In the former case potential distribution is all too often minimised and based on

unsubstantiated assumptions of dilution (seawater discharges) or slick dissipation (evaporation, dissolution or flushing fro, bay waters).

3.1.4 In the latter case computer modelling is used (seawater discharges). In the case

of oil spills, the EES implies that some modelling has been undertaken but presents no model output of commissioned reports (see Section 3.2).

3.2 Fire Foam and Fire Related Discharges 3.2.1 No assessment (modelling or otherwise) of the fate or possible distributions of

fire foams is provided in the EES. 3.3 Oil Spills 3.3.1 It is unclear whether any modelling of oil spills has been undertaken by the

Proponents. 3.3.2 An assessment of consequences has been made for a credible spill of 30 tonnes

of diesel over a period of three hours from a breached diesel storage tank on an LNG carrier near McHaffie’s Reef EES S6.5.5 pp 6-111

3.3.3 No indication of why a 30 tonne spill was considered or why the release over a

three hour period was selected. This does not state that modelling was undertaken, indeed it seems that no oil spill trajectory modelling was done for this EES, and no information to how this “assessment” was undertaken is provided.

3.3.4 The hydrodynamic modelling report (Technical Appendix A, Annexure A-H) does

not address diesel or other spills. 3.1.5 “ Diesel spilled into marine waters would spread over the surface, evaporate

(loss of about 40 per cent over 10 hours) and mix vertically down into the water column. ”

(EES S6.5.5 pp 6-111).


26

3.1.6 The source of these figures is not provided. Modelling done for the Victorian

National Parks Association (APASA, 2013) suggest lower evaporation rates of about 15% in 10 hours and reaching a peak of about 45% after 60 hours at sea. It should be noted that the APASA report used a light diesel (SG of 0.8291), probably a gasoil. Evaporation rates for Marine Diesel Oil (MDO) can be expected to be lower.

3.1.7 Modelling using the Adios 2 program (developed by the US National

Oceanographic and Atmospheric Association, NOAA) indicates that at 15oC and assuming 12 knot winds (the same as used for the APASA modelling) indicate the evaporation rates shown in Table 5.

Table 5 Indicative Evaporation Losses for Two Marine Diesel Fuel Oils

(12oC Temperatures and 12 Knot Winds)

Time After Spill Marine Diesel Oil Type

Specific Gravity

(Oil Density) 6hrs 12 hrs 24 hrs 48hrs

MDO F-76 0.873

(API 31.6) 8 18 21 22

No 2 Marine Fuel Oil (US

MGO)

o.83 (API 39)

23 33 33 33

3.1.8 The evaporation rates assumed in the EES for marine diesel oil are considered

to be too high and underestimate the persistence of diesel at sea and therefore underestimate the trajectories and effects of such spills.

3.1.9 Statements regarding vertical entrainment of diesel are provided throughout the

document and all seem high with dilution rates that may (or may not) be based on the hydrodynamic modelling.

3.1.10 However, entrained oil is not dissolved and is not in the form of a micro-

suspension. It is buoyant, can adhere to substrates and suspended particulates and will resurface under calm conditions. It is not “lost”.

3.1.11 Calculations of possible effects of diesel at sea based on vertical distribution

and dilution rates and assuming that the diesel is present in a dissolved or water miscible form (oil in water suspension) substances are not valid.

3.1.12 This entire assessment seems to be premised on a series of unsupported

(almost certainly baseless) assertions. 3.1.13 Using published evaporation and dispersion rates, the indicative diesel

concentration would be around 100 mg/L at 100 metres distance, 5 mg/L at 500 metres, 0.7 mg/L at 5 kilometres and 0.1 mg/L at 10 kilometres distance. ”

(EES S6.5.5 pp 6-111).


27

3.1.14 No indication of what these published rates are is provided. The reference to

“concentrations” suggests that this refers to diesel in the water column. The presence of diesel on the surface seems to have slipped from consideration.

3.1.15 “ Diesel is more toxic than hydraulic fluid. If a spill of diesel did occur, a

localised effect at the site of the spill would be expected. In a typical tidal current, or even with surface spreading and local wind mixing, the diesel would

disperse within 10 minutes over an area of around 30 m2 and a depth of approximately two metres, with a resulting concentration of 500 mg/L ”. (EES

Section 6.6.5 .page 6-108). 3.1.16 No technical support for these predictions is provided. 3.1.17 “ Approximately half the diluted diesel would be flushed to Bass Strait within 24

hours and the remainder would spread around Phillip Island and, to a limited extent, into North Arm of Western Port. ” (EES S6.5.5 pp 6-111).

3.1.18 The possibility of flushing from Westernport waters is highly dependent on the

location of the modelled scenario and also the time of any release, particularly the tidal conditions at the time of the spill and in subsequent hours. It is quite probably that some oil will enter Bass Strait if a spill occurs at McHaffies Reef (or the Nobbies or Tortoise Head) on an outgoing tide. This may be good news for some Westernport shorelines but certainly isn’t for the penguins of the region or for southern Phillip Island coastlines (including the Penguin Parade). The EES needs to consider more than Westernport bay shorelines.

3.1.19 Surprisingly, this scenario is not addressed in the Sections of the EES dealing

with impact assessment nor those Sections dealing with spill management strategies.

3.1.20 Figure 2 provides some of the output from the APASA report which has

relevance to the current basement of the EES. Again, it should be noted that the diesel type modelled was light and consequently the modelled distribution may be slightly less than would be achieved with a heavier marine diesel oil (MDO).

3.1.21 Modelling of oil spillages has not been undertaken. No serious attempt to define

‘zones of potential impact” for various spill scenarios. 3.1.22 Presented data is unsubstantiated and of little value in identifying natural

resources at risk or developing spill response strategies.


28

Figure 2 Surface Diesel Modelling Output from APASA 2013 Spill location “Long Point” (Long Island Point) approximately 10km north of Crib Point.

(Note the diesel modelled was a light product with an SG of 0.8291)

1 A “concentration of 25g.m2 equates to a thickness of 0.03mm of diesel based on the diesel

SG of 0.8291 noted in APASA 2013. This would be visible as silver or rainbow sheen. 2 This output is very similar to the modelling undertaken for the Crib Point Terminal plans (see Section8), undertaken twenty years before.


29

4.0 IDENTIFICATION OF RECEPTORS, (RESOURCES LIKELY TO BE IMPACTED) 4.1 Overview 4.1.1 EES Chapter 6 and Technical Report A provide a detailed description of the

Westernport Bay natural environment. 4.1.2 Section 6 and Attachment III (Appendix B) identify broad groups (habitats or

populations) that could be affected by identified discharges and provides a summary of the risk assessment (refer to Section 5): These are summarised in Table 6.

Table 6 Summary of Identified Natural Resources and Risk Assessments

(Based on EES Section 6 Table 6-11 and Technical Report A)

Risk (EES) Assessment and Analysis

Receptors Initial Residual

Risk ID EES References

Discharge

Bioaccumulation Low Low ME40 TRA Sec 7.8.25 Spills (Constr’) 1

Low Low ME41 None presented

Spill (Ops)

See Note 3 and 4

Low Low ME42 None presented Spills from vessels

See Note 2 and 4 Medium Medium ME43

No analysis presented

Hull and prop cleaning runoff

See Note 2 and 3 Low Low ME44


1 No trajectory modelling or identification of ‘receptors’ at risk from non-routine discharges has been undertaken. 2 No identification of materials that could be spilt is provided and hence no assessment of behaviour, fates and effects is possible 3 Transfer procedures for lubricating oils and other chemicals (not identified in the EES) need to be set out so that a spill risk assessment can be undertaken. 4.2 Non Routines Discharge Receptors 4.2.1 The EES clearly acknowledges the sensitivity of Westernport Bay to oil spill

impact: 4.2.2 “ All coasts and estuaries are sensitive to spills of oil, diesel, other liquid fuels

and other chemicals. Western Port is particularly sensitive because of the large intertidal mudflats, fringing mangroves, seagrass close to the water surface at low

tide and the importance of the coastal areas to birdlife ” (EES Section 6.5.5). 4.2.3 Despite this there is no systematic identification of species or groups of species

that are particularly vulnerable and sensitive to oil spill impact.


30

4.2.4 Consequently there is no systematic, detailed, assessment potential effects of

spills on these species (see Section 5). 4.2.5 Some candidates for detailed assessment are obvious: 1. Mangroves. Effects of oil on these are well studied and there are a number of

well documented post spill reports and controlled studies dealing with the effects from diesel oils. These are identified n Technical Report A but no analysis of risks seems to have been undertaken.

2. Seagrasses, particularly intertidal and emergent forms. Again there is a large body of scientific literature is available.

3. Saltmarshes. These are also identified in Technical Report A but no analysis of risks seems to have been undertaken.

4. Birds, particularly; Diving birds. Penguins. Nesting birds. Waders.

5. Marine mammals. 4.2.6 The EES has made little attempt to identify species that could be impacted by oil

(either surface or subsurface oil) and does not provide a foundation for subsequent impact assessment. Consequently, the assessments of potential effects (see Section 5) is limited and inadequate


31

5.0 ASSESSMENT OF POTENTIAL ENVIRONMENTAL EFFECTS 5.1 Overview 5.1.1 Assessments of marine discharges are summarised in EES Section 6.4 to 6.7

and discussed in EES Technical Report A, Annexure A-H and EES Attachment III.

5.1.2 EES Table 6-11 presents a summary of the risk assessment findings as per

Appendix B of EES Attachment III. 5.2 Assessment of Construction Phase Non Routine Discharges 5.2.1 EES Section 6.5 “Construction impacts”, contains no assessment of the

potential discharges noted in Section 2 of this document (see also Table 1). 5.2.2 Only one construction stage risk to the marine environment is noted in Table 6-

11: 5.2.3 “ ME41 Hazardous material or waste spill/leaks. Accidental spills or leaks

from chemicals or waste streams into Western Port during construction. ’ 5.2.4 Although non routine (spill) risks are briefly noted they are in no way assessed.

Instead the EES assures us that: 5.2.5 “ A Construction Environmental Management Plan (CEMP) would be prepared

to ensure that work practices are put in place to avoid or minimise the potential occurrence of these types of small spills during construction. The CEMP would be risk-based, including identification description of contaminant sources and

impact pathways. ” (EES Section 6.5) 5.2.6 Surely “identification description of contaminant sources and impact pathways”

is the primary function of, and should be addressed in, the EES. 5.2.7 The EES contains little or no assessment of potential construction stage

discharges of their potential effects. 5.3 Non Routine Operations Phase Discharges 5.3.1 Fuel Oil Spills 5.3.1.1 Assessments of oil spill effects tend to be repeatedly based on: A statement of how unlikely the spill is – with no supporting data, or selective

data. An off-the cuff (un-modelled) statement of where the oil will go both in terms

of trajectory and position in the water column. A statement that effects will be minimal or localised


32

(no modelling again); often with reference to unsupported concentrations in

the water column and vague reference to available information or other studies which are not cited or referenced.

A general failure to address the effects of surface oil on biota such as birds. An assumption that diesel will somehow be diluted or otherwise ‘go away’.

5.3.1.2 The assessment of oil spill risks is the weakest part of the EES and is

supported by little or no real analysis. For example: 5.3.1.3 “ In the very unlikely event of a spill from an LNG carrier during operation,

major short term impacts would be expected on the biota in the water column and on the shoreline of Phillip Island within a distance of about five kilometres either side of the spill (based on the short term EC50 of one to 100 mg/L for

most marine biota). Minor short-term effects are expected within a distance of 10 kilometres. Beyond this distance, there would be no visible slick, and little effect on birds or intertidal biota. The effects are likely to persist for up to one kilometre from the spill for weeks to months. Longer term, there would be full

recovery. ” (EES S6.5.5 pp 6-111). 5.3.1.4 It is unclear under what conditions this scenario is considered. It is unclear why

biota in the water column would be affected by a surface spill of diesel – unless vertical mixing (i.e. wave action) was high.

5.3.1.6 The basis for predicting a shoreline impact on Phillip Island only, and in such a

limited area, is also questioned as no scenario (cause and location) and associated modelling is presented.

5.3.1.7 Modelling undertaken for other project (Crib Point, 1994 and APASA, 2013)

indicate potential impacts on the shorelines of French Island, Phillip Island, Quail Island, North Arm, Western passage and the northeast mudflats, depending on the spill location and tidal conditions modelled.

5.3.1.7 Proper modelling should be undertake (multiple scenarios) in order to identify:

All shorelines and water bodies that are vulnerable to impact.

High risk shorelines, based on the most likely locations and tidal conditions. Shoreline impact times, so that response actions can be developed and

assessed properly. Most vulnerable habitats and species, also considering seasonal factors.

5.3.1.8 The use of EC50 data indicates that the relating to anticipated damage to biota

refers to subtidal biota only (although this is not stated). ‘Short term EC50’ is, in any case, irrelevant to an assessment of biological damage from oil(see Attachment A).

5.3.1.9 No assessment is presented regarding potential damage to coastal habitats

(mangroves, saltmarsh, intertidal and emergent seagrass meadows and mudflats) or associated species.


33

5.3.1.10 The EES should assess biological and ecological damage based on a

thorough review of the available scientific literature (including post spill case studies, controlled field experiments and laboratory data) relating to the identifies habitats and species. This could be interpreted with reference to proper modelling of the weathering of diesel oil between spillage and impact).

5.3.1.11 The assertion that “short-term effects will be limited to a distance of 10km” is

not supported by any modelling or calculations of oil distribution (neither surface oil or any oil entrained in the water column).

5.3.1.12 Similarly the statement that surface oil will not be visible beyond this 10km

distance is not supported by modelling or other calculation presented. In any case, slick visibility is irrelevant to any assessment of damage to intertidal biota and birds have a tendency to be mobile and not excluded from this proposed 10km distance. The area represented by this 10km is not defined.

5.3.1.13 The assertion that (non “short-term”) effects will only occur within 1km of the

spills site and that effects will only last for at most months with longer term “full recovery” is not supported by any data (modelling, scientific reports or even anecdotal) and really has no basis in fact, and:

5.3.1.14 “ The likelihood for contamination due to leaks or spills of significant quantity

from vessels to occur is ranked as rare. The consequence for a spill is ranked as major. According to the risk matrix, a rare likelihood and major

consequence results in a risk rating of medium. ” (EES S6.5.5 pp 6-111 Assumptions).

5.3.1.15 The EES fails to define what is meant by a “significant quantity” and so the

frequency is difficult to calculate or guess. 5.3.1.16 The use of simplistic risk matrices is in itself problematic. It has value in

assessing workplace or facility safety risks but is not suitable for health (community or individual) or ecological risk assessment.

5.3.1.17 The occurrence of a single “rare” event can have serious immediate and long

term effects to individuals, communities and the environment. Worst case scenarios need to be considered in any environmental assessment and the EES fails to do this.

5.3.2 Lubrication Oils 5.3.2.1 Lubricating oils are generally insoluble and have a high spreading coefficient.

Consequently, the trajectories of spilt lubricating oils will be similar to those of diesel spills at the FSRU/jetty.

5.3.2.2 By virtue of the greater potential volumes, diesel fuel spills would be

considered “worst case” and no additional modelling would be necessary had diesel spill scenarios been modelled.


34

5.3.3 Hydraulic Fluid 5.3.3.1 “ According to the Material Safety Data Sheet (MSDS) for hydraulic fluid, it

has a 96-hour lethal concentration 50 (LC50) of more than 1000 mg/L (Oncorhynchus mykiss) and a 48-hour median effective concentration (EC50) of more than 1000 mg/L (Daphnia magna). If a spill of hydraulic fluid did occur, given the rapid dilution of hydraulic fluid in currents underneath the jetty, there could be a very localised effect. Within a few minutes the fluid would mix with over 10 m3 of seawater and the mixture would be below the LC50 and EC50

values described above. ” (EES Section 6,6.5).

5.3.3.2 No MSDS is supplied and it is unclear what product this refers to. 5.3.3.3 Oncorhynchus mykiss (rainbow trout) and Daphnia magna (water flea) are

both common freshwater test animals. The use of an EC50 rather than an LC50 for Daphnia suggests that immobility rather than mortality was measured for tis MSDS. This is common in Daphnia based tests but makes extrapolation of the data to other species in the natural environment difficult.

5.3.3.4 Again, it is unclear what product is intended for use and therefore the

relevance of the presented MSDS data is unclear. Since some hydraulic fluids are water soluble (water-glycol based products) and miscible, and others (hydrocarbon based) are not, interpretation of the data is impossible (see Attachment A).

5.3.3.5 It is acknowledged that low toxicity water soluble hydraulic fluids are available.

If these are to be used then this should be clearly stated (and committed to) in the EES.

5.4 Potential Long Term Effects 5.4.1 Technical Report A (Table 2.1, Section2.2) notes that a key issue to be

addressed by the Marine Biodiversity Impact Assessment is an assessment of the long term effects on biota due to entrainment, water quality (unspecified except for temperature). These are addressed in Section 7 of Technical Report A.

5.4.2 Long term effects from spills and other discharges does not appear to have

been a consideration for the EES. Despite no assessment, Technical Report A concludes:

5.4.3 “ In summary, it is considered that the Project would not result in

unacceptable or long-term impacts to the marine environment of Western Port. The recommended mitigation measures and monitoring programs would

avoid and minimise potential adverse effects to native flora and fauna and their habitats, on water quality and the Western Port Ramsar site. ” (EES

Technical Report A, Section 8.7).


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5.5 Cumulative Effects 5.5.1 Cumulative impacts are addressed in EES Section 66.8 and in Technical

Report A, Section 8.5 and deal only with the combined effects of the routine discharges from the Project.

5.5.2 Cumulative effects from non-routine discharges (e. repeated spills) are not

addressed. 5.6 Presentation of Assessment Data 5.6.1 The use of tables (Technical Report A, EES Table 7-11) showing large lists of

potential risks along with qualitative assessments of significance are problematic.

5.6.2 The inclusion of risks that most people would consider trivial and then

summarily labelling them as of “very low” significance gives the impression that the assessment is thorough (in scope) but belies the fact that the assessments usually lack any scientific rigour. In the case of non-routine discharges the assessments have no substance at all.


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6.0 PROPOSED MANAGEMENT STRATEGIES FOR NON ROUTINE DISCHARGES

6.1 Overview

6.1.1 “ Mitigation measures relating to marine biodiversity impacts are presented in Section 6.8 (Mitigation measures) and in Chapter 25 Environmental

Management Framework. ” (EES Section 6.4).

6.1.2 Section 6.8 consists almost entirely of Table 6-23 which:

6.1.3 “ sets out the recommended mitigation measures developed to avoid, minimise and manage potential marine biodiversity impacts during construction and

operation of the Project. ”(EES Section 6.8).

6.1.4 It is unclear why only “recommendations” are listed rather than commitments to mitigation strategies.

6.1.5 Annoyingly, Table 6-23 does not list the risks or discharges that each mitigation measure is meant to address requiring the reader to continually refer back to Table 6-11. This is made more difficult because the Risk ID (ME2 to ME53 in Table 6-11) do not correspond to the ME numbers in the MM-ME codes used in Table 6-23.

6.2 Construction Phase

6.2.1 As noted earlier, Table 6-11 presents only one construction–related risk: ME41 hazardous material or waste spill/leaks. According to Table 6-23, this is addressed mitigation measure MM-E05 in the first instance and then by MM-ME06. The EES states that spill risks are minimal because:

6.2.2 “ All vessels will comply with the Port of Hastings Development Authority Safety and Environmental Management Plan and Port Operating Handbook ”

(MM-ME05 in EES Table 6-23_.

6.2.3 The current version of the Port of Hastings SEMP (PoHDA, 2018) deals with Emergency management and Oil Spill Response in Sections 2.4.2 and Section 3 Emergency Management. Section 2..4.2 states in its entirety:

6.2.4 “ PoHDA is also the Coastal Regional Control Agency for Level 1 Maritime Emergencies (non-search and rescue) on behalf of the Department of

Economic Development, Jobs, Transport and Resources (DEDJTR) for the waters of Western Port and coastal waters extending three (3) nautical miles

from the coastline between Cape Schanck to Wilson Promontory. Any oil pollution to marine waters in the regions must be reported to PoHDA, who will

then verify the spill and report to the Victorian Environment Protection Authority (EPA), Transport Safety Victoria (TSV) and Australian Maritime Safety Authority

(AMSA). “

6.2.5 Section 3’s contribution to oil spill response planning is the statement:


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6.2.6 “ For any oil spill, PoHDA will follow the States Emergency Management Plan

for Maritime Emergencies – Non-Search and Rescue. “ 6.2.7 Needless to say, the State Plan does not cover spill response in Westernport

Bay. 6.2.8 The Port of Hastings Operating Handbook does not deal with spills except o

note the possible requirement of port users to have a suitable plan (see Section 6.2.2.1 of this Report).

6.2.9 It should also be noted that not all potential spill sources are vessels and so an

intent for vessels to comply with largely irrelevant plans is not sufficient. A more general and more definite commitment to spill response during construction is required.

6.2.10 “ Compliance with the environment management plan, regulations or policies

The operation of the FSRU and LNG carriers proposed to enter, moor and depart the Port of Hastings will be consistent with present and past operations

within the port. Operation will comply with the same port and state environmental guidelines, regulations and environmental management plans as

other similar vessels.” MM-ME06 in EES table 6-23 6.2.11 With respect to managing spill risks during construction, this is meaningless 6.2.12 Table 16-3 also notes that an Emergency Response Plan will be developed and

implemented for the construction phase but nowhere in the EES are the potential materials which could be released identified, nor are appropriate responses outlined.

6.2.13 Responsibility for developing the Emergency Response Plan(s) for construction

activities is not clearly assigned but are presumably the responsibility of the relevant contactors.

6.2.14 Protocols or procedures for quality control or approval of these plans is not

mentioned in the EES. 6.2.15 Responsibilities for development of Emergency Response Plans (ERPs) should

clearly assigned. 6.2.16 The Proponent should set out guidelines for ERPs and include these in the

EES. 6.2.17 Quality control and approvals protocols should be set out. 6.2.18 Responsibilities for response, costs and compensation should be set out

together with insurance requirements to cover these. 6.2.19 The EES does commit to the preparation of response plans:


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6.2.20 “ A Construction Environmental Management Plan (CEMP) would be prepared

to ensure that work practices are put in place to avoid or minimise the potential occurrence of these types of small spills during construction. The CEMP would be risk-based, including identification description of contaminant sources and

impact pathways. The CEMP would include prevention, management, minimisation and actions relating to potential impacts of spills/leaks on the

environment during construction. ” (EES Section 6.5) 6.2.21 It is worth noting that the plan will be risk-based, including identification

description of contaminant sources and impact pathways. This should have been done for the EES.

6.3 management of Operations Phase Non Routine Discharges 6.3.1 Table 7 summarises the Risks and management strategies relating to non-

routine discharges as outlines in the EES.

Table 7 Summary of Proposed Mitigation Strategies as Set out in the EES

Mitigation Measure (Table 6-23)

Discharge or Activity (Tables 2)

Risk ID (Table 6-11) Initial Additional

Oil and hazardous materials spills

ME41 to 43 MM-ME05 MM-ME06

Hydraulic fluid spills Not listed None Firewall runoff during fire response

Not listed None None

Fire foam discharges Not listed None None 6.3.2 A number of statements in the EES make it clear that the Proponents will have

a spill response plan but in others this intent is unclear: 6.3.3 “ Any oil spills would be managed by PoHDA and Australian Maritime Safety

Authority (AMSA) and there is a comprehensive AMSA spill management plan for Western Port. ” (EES Section 6.5.5 pp 6-110).

6.3.4 It should be noted that there is no AMSA oil spill management plan for

Westernport, comprehensive or otherwise. 6.3.5 The Port of Hastings Operating Handbook Section 8.7 states that: 6.3.6 “ If required by PoHDA, Long term Port Users must prepare and provide

PoHDA with a detailed emergency management plan(port User Emergency Plan)that sets out the systems, practices and procedures that will apply to the emergency management of the area of the Port used by the Long Term Port

User (Security Area). ”


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6.3.7 This suggests that a response plan may be optional. However, Section 9.2(a)

states that: 6.3.8 A Port User must ensure that it and all of its Associates:

i Do all things reasonably necessary to prevent pollutants or contaminants from escaping onto PoHDA's land or into the Port Waters or into the air surrounding the Port; ii. Do all things reasonably necessary to contain, minimise the effect of and remove pollutants and contaminants from PoHDA's land or the Port Waters if any pollutants or contaminants escape because of any act or omission by the Port User or any of its Associates; iii. Comply with in the event of an oil spill, any directions given by the Oil Spill Response Contractors; and iv. Comply with any requirements relating to pollution and contamination set out in the Victorian Contingency Plan for Marine Pollution. ”

6.3.9 The current Maritime Emergencies (NSR) State Emergency Response Subplan

also makes it clear that spills at a facility are the responsibility of the facility operator (page 34) and that

6.3.10 “Facility includes, but is not limited to a wharf or mooring at which a vessel can

be tied up during the process of loading or unloading a cargo. ” 6.3.11 The EES should state clearly that the Proponent will develop a spill response

plan together with its format (e.g. a stand alone plan or part of an overarching emergency plan). The EES should set out the arrangements and responsibilities of contractors and provide some idea of the level of response that will maintained.

6.3.12 This should be based on an adequate risk assessment. 6.3.13 The EES also needs to make clear whether its response plan covers shipping

to the facility (LNG tankers and tugs). 6.3.14 The IMO. International Protection of the Sea (Prevention of Pollution from

Ships) Act 1983 Convention for the Prevention of Pollution from Ships (MARPOL) 1973 and the Commonwealth does require ships greater than 400 tonnes gross to have pollution emergency plans.

6.3.15 “ In the event of a spill, and in accordance with the prevailing International

Maritime Organisation (IMO) Marpol requirements, all vessels are equipped with a Shipboard Oil Pollution Emergency Plan (SOPEP) which provides

guidance to the crew onboard on the measures to be taken if an oil pollution incident has occurred or is likely to occur. The SOPEP address various

scenarios such as transfer system leaks, tank overflow, fuel tank / hull leaks from penetration and the like and also contains an overview of the oil spill

response equipment available onboard the vessel. ” (EES Section 6.5.5 pp 6-112).


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6.3.16 It should be noted that Shipboard Oil Pollution and Emergency Plans (SOPEP)

deal with spills to deck and almost never address spills over the side. Most vessels carry no oil spill response equipment for cleanup of oil on the sea – unless they are contracted as a spill response vessel.

6.3.17 The EES should note whether any tugs or other contracted vessels will have an

oil spill response role and whether they would carry response equipment. 6.2.18 The EES has not cover spill response commitments and arrangements in any

detail or with any clarity.


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7.0 SUMMARY AND CONCLUSIONS The management of non-routine discharges is a critical component of an

environmental effects assessment (and an EES). Key findings of this review are as follow.

7.1 Construction Phase Non-Routine Discharges 7.1.1 1. The EES does not provide a list of hazardous materials to be used or stored

on the various work sites. This should be provided, together with volumes of on site storage.

2. A construction site map showing location of hazardous materials storage, coupled with the site drainage map noted in Section 2.2.4.1, is also needed if risks are to be quantified.

3. No assessment of construction stage spill scenarios or associated risks has been undertaken in the EES.

4. No details of the products potentially spilt and no assessment of volumes or potential scenarios is presented.

5. No justification for assigning the “Low” initial and residual risk value is provided but appears to be based only on an assumption of low frequency and low volumes.

6. EES Table 6-11 lists the “Port of Hastings Handbook” and a future :environment management plan, regulations and policies as the mitigation tools considered in the assessment of risk.

7. The PoH Handbook (does not address spill response and so is irrelevant. 8. It is unclear what regulations and policies are being referred to and no details

of, or clear commitment to, any environmental management plan is provided.

9. The position with regards emergency management during construction stage of the Project is extremely unclear in the EES.

10. A clear and consistent statement is required in the EES setting out responsibilities for development of Emergency Response Plans (ERPs) should clearly be assigned.

11. The Proponent should set out guidelines for ERPs and include these in the EES.

12. Quality control and approvals protocols should also be set out. 13. Responsibilities for response, costs and compensation should be set out

together with insurance requirements to cover these. 14. Overall, the EES coverage of construction stage discharges is inadequate. 15. None of the five key tasks considered necessary for an adequate

assessment of environmental risks have been undertaken. 16. Management of non-routine discharges and other emergency situations is

particularly poorly explained 17. No assessment of environmental risks can be made on the basis of the

supplied information.


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7.2 Operations Phase Non Routine Discharges

7.2.1 Discharges during fire events:

1. Potential volumes of fire foam that could be released during a fire responseare not calculated and so potential effects cannot be calculated.

2. The EES should calculate potential losses of fire foam to Westernport baywaters during fire events and present an assessment of potential effects.

3. Details of the type of fire foam to be used and its toxicity to marine biotashould be assessed in the EES.

4. Containment strategies are not stated. EES Technical Report K states thatfire foam losses during a fire response would be minimised “to an extentthat is practicable”. No indication of what is practicable is given.

5. No assessment of the effects of fire foam losses can be made on the basisof the information provided in the EES.

7.2.2 Fuel and other spills

1. Spill effects and spill managements methods are dealt with in an extremelycursory and dismissive manner throughout the EES. Sections that doaddress the issue are amongst the weakest in the entire document.

2. Oils identified in the EES are diesel fuel oil, lubricating oil and hydraulicfluid. Each of these can vary in their character and consequent behaviourin the environment and this will influence the scope and d nature of anyeffects on the environment

3. Again, no other hazardous substances (chemicals) are identified.4. The EES should specify the oils to be used and provide full specifications

for each.5. The EES should include a full inventory of chemicals used and stored at the

proposed facility and clearly identify those that could, under any scenario,bee spilled into Westernport Bay.

6. The potential spill volumes provided in the EES do not relate to theproposed Project and do not allow an adequate assessment of spilltrajectories, fates or effects.

7. Potential spill volumes have not been calculated with reference to credibleor worst case scenarios. Indeed few scenarios are considered at all. .

8. The EES does not contain any shipping risk assessment. Such riskassessment should identify other hard grounding sites (The Nobbies,Tortoise Head) and potential soft grounding sites and possible high riskareas or operations for vessel-vessel conditions. This would provide somebasis for calculation of potential spill volumes, trajectory modelling and avalid assessment of environmental risks

9. The information provided in the EES regarding the character of oil andchemicals does not allow an adequate assessment of spill fates or effects.

10. Modelling of oil or chemical spillages has not been undertaken. No seriousattempt has been made to define ‘zones of potential impact” for the variousoil types or potential spill scenarios.

11. The data that is presented is unsubstantiated and of little value in identifyingnatural resources at risk or developing spill response strategies.


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12. Proper modelling should be undertaken (multiple scenarios) in order to

identify: All shorelines and water bodies that are vulnerable to impact. High risk shorelines, based on the most likely locations and tidal

conditions. Shoreline impact times, so that response actions can be developed and

assessed properly. Most vulnerable habitats and species, also considering seasonal factors.

13. The EES use of past modelling efforts based on scenarios of limited relevance to the proposed Project is not justifiable and does not assist in the assessment of effects. Modelling output from the APASA study directly contradicts the assertions in the EES regarding spill trajectories.

14. This selective use of available data does not inspire confidence in the integrity of this part of the EES.

15. In the case of hydraulic fluid (if deemed significant) 3-dimensional modelling should be undertaken as these are water miscible.

16. The EES has made little attempt to identify species that could be impacted by oil (either surface or subsurface oil) and does not provide a foundation for subsequent impact assessment.

17. Ideally this should be done with reference to trajectory modelling to identify shorelines but some highly sensitive and vulnerable receptors such as birds (and particularly penguins) are obvious.

18. As a consequence of this deficiency in the EES, any assessments of potential effects of spills will be limited and inadequate.

19. The EES should assess the potential biological and ecological damage based on a thorough review of the available scientific literature (including post spill case studies, controlled field experiments and laboratory data) relating to the identifies habitats and species.

20. This should be interpreted with reference to the character (chemical and physical) of the products, proper modelling of trajectory and weathering of spill and the modelled time between spillage and impact.

21. Risks from spills are minimised and dismissed on the basis that they are rare events. Consequently, even in the case of potentially major consequences the overall risk is estimated as ‘moderate’ (or medium).

22. The past spill record of marine operations in Westernport is used to show the rarity of spills but draws only on anecdotal information from the past three years. Yet accurate records going back many years are available. This highly selective use of data is a low point in the EES and at best show a lack of diligence on the part of the Proponents.

23. The EES should present an accurate record of spills (oil types, volumes and sources) based on the readily available spill records for marine and port activities in Westernport Bay.

24. While some references are made in the EES to a future emergency response plan other parts of the EES imply or state that spill response is the responsibility of others.

25. The EES needs to make it clear that the Proponent will prepare an spill response plan and ensure that spill response arrangements, personnel and equipment will be maintained as per the requirements of the Port of Hastings Operating Handbook and the Victorian Maritime Emergencies (NSR) State Emergency Response Subplan.


44

26. A number of misleading statements in the EES should be removed or corrected: Statements that AMS (PoHDA will manage all spills in Westernport bay. Reference to a (non existent) AMSA spill plan for Westernport Bay. The inference that Shipboard Oil Pollution and Emergency Plans

(SOPEPs) address spills ‘over the side. They do not cover at sea responses.

7.3 General Comments on Presentation of Information in the EES 7.3.1 The size of the EES is daunting but not in itself problematic. Generally, the

Technical Reports stand alone and the relevant parts can be located. However, a lot of information is needlessly repeated in the main document – usually word for word but often with additional inconsistent ‘information’ or explanation added.

7.3.2 The numerous instances of inconsistent data is a problem but is compounded

by the total lack of cross referencing within the main EES documents. 7.3.3 The EES presents a lot of information but uses relatively little of it in the

assessment of environmental effects. The assessment is not thorough: 7.3.4 Generally, long term effects are inadequately addressed.

Far too many issues are given superficial consideration and the EES is peppered with qualitative and unsupported assertions, only temperature and chlorine effects are assessed quantitatively.

Long term effects from non-routine discharges are not addressed. Cumulative effects from discharges from all Westernport Bay users are not

addressed. Cumulative effects from non-routine discharges are not addressed

7.3.5 There are significant gaps in the presented data. These are noted throughout

this Report. 7.3.6 Information is not presented clearly and concisely: The use of tables (EES Section 6 Table 6-11 and 6-23) showing large lists of

potential risks along with qualitative assessments of significance are problematic.

The inclusion of risks that most people would consider trivial and then summarily labelling them as of “very low” significance gives the impression that the assessment is thorough (in scope) but belies the fact that they usually lack any scientific rigour. None of this data is presented and no such analysis seems to have been undertaken.

7.3.7 The use of simplistic qualitative risk assessment matrices to determine overall

risks is not appropriate to environmental effects assessments. They are not applicable in many non workplace situations at all.


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7.3.8 There is a general lack of rigour in the assessments. 7.3.9 Sections dealing with spill response (oil and chemicals) show an almost total

lack of knowledge of the subject and there are several ‘throw-away” comments that are totally incorrect and misleading.

7.3.10 The use (misuse) of third part modelling and highly selective interpretation of

the data is of grave concern.


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8.0 REFERENCES 8.1 APASA. 2013. Quantitative Assessment of Exposure Risks due to Oil Spills from

Shipping in Western Port Bay, Report to the Victorian National Parks Association. Asia-Pacific Applied Science Associates, Perth, Western Australia.

8.2 British Columbia 1989. Ambient Water Quality Criteria for Chlorine. 8.3 Crib Point Terminals Pty Ltd. 1994a. Oil Spill Prevention and Response Plan:

Strategy Plan. 8.4 Crib Point Terminals Pty Ltd. 1994b. Oil Spill Prevention and Response Plan:

Contingency Plan. 8.5 Crib Point Terminals Pty Ltd. 1994c. Oil Spill Prevention and Response Plan:

Contingency Plan Appendices. 8.6 Emergency Management Victoria. 2016. State Maritime Emergencies (Non

Search and Rescue) Plan Edition 1. 8.7 Environment Canada. 1999. Canadian Water Quality Guidelines for the

Protection of Aquatic Life: Reactive Chlorine Species. 8.8 Environment Protection Authority Victoria (EPA). 2008. Port Phillip Bay and

Western Port Marine Condition Report. EPA Report for the Development of the Better Bays and Waterways Program.

8.9 Kellogg Brown & Root, 2010, Western Port Ramsar Wetland Ecological Character

Description. Report for Department of Sustainability, Environment, Water, Population and Communities, Canberra.

8.10 Port of Hastings Development Authority and Victorian Regional Channels

Authority. 2018. Safety and Environment Management Plan Revision 1. POH-HSE-PLN-002.

8.11 Port of Hastings Development Authority and Victorian Regional Channels

Authority. 2019. Port of Hastings Operating Handbook. POH-OPR-PRO-001. 8.12 Toll Western Port. 2001. Draft Environmental Management Plan for the Port of

Hastings. 8.13 VNPA. 2014a. Shipping Oil Spill Impacts on Westernport Bay, Victorian National

Parks Association, Carlton, Victoria. 8.14 VNPA. 2014b. Oil Spill Impacts on Westernport: Seagrass, Mangrove and

Saltmarsh. Victorian National Parks Association, Carlton, Victoria. 8.15 VNPA. 2014c. Oil Spill Impacts on Westernport: Bird Species. Victorian National

Parks Association, Carlton, Victoria.


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8.16 VRCA 2017 Hastings Safety and Environmental Management Plan (SEMP)

Summary. Victorian Regional Channels Authority. 8.17 Wang, J,C.A. Jia, C.K. Wong and K. Wong. 2000. Characterisation of Polycyclic

Aromatic Hydrocarbons Created in Lubricating Oils.. Water, Air, and Soil Pollution 120: 381–396.

8.18 Melbourne Water and Port Phillip and Westernport CMA. 2020. Understanding

the Western Port Environment: A Summary of Current Knowledge and Priorities for Future Research


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9. STATUTORY DECLARATION

I have made all the inquiries that I believe are desirable and appropriate and no matters of significance which I regard as relevant have to my knowledge been withheld from the Panel.’

Signed:

John A Wardrop Date: 30/09/2020


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ATTACHMENT A:

THE USE OF TOXICITY DATAIN OIL SPILL EFFECTS STUDIES

A.1 Definitions A.1.1 Toxicity is a measure of the harmful effect of a given substance on a particular test organism or (more rarely) on a set off organisms. A.1.2 Test organisms vary greatly in their sensitivities and so care needs to be taken in extrapolating toxicity data from one organism to another, particularly if the organisms are unrelated or inhabit different mediums (i.e terrestrial, freshwater of marine). A.1.3 One of a number toxicity values can be obtained, including:

Lethal dose: Used when the substance being tested is given to the organism (e.g. via injection, ingestion etc). The intake by the organism is known or measured. An LD50 is the dose at which 50% of the test organisms die.

Lethal concentration: Used when the test substance is a gas or in a liquid (e.g. freshwater or seawater). The concentration of the substance is measure and of course it is assumed that as this rises the uptake by the test organism also rises. An LC50 is the concentration at which 50% of the test organisms die.

Effective Dose: This is used when an effect other than death is being measured. Effective concentration: This is used when an effect other than death is being

measured. Threshold level: The does or concentration below which death or effect is not

noted in the test organism. Caution the threshold level can be time dependent A.1.4 Note death or effect will occur in some test organisms at doses and concentrations above the threshold effect. An LD50 or LC50 is not indicate that there is no effect or even an “acceptable” effect below that dose or concentration. A.1.5 Toxicity can be:

Acute: Measured over a short term (short term exposure) or Chronic: Long term exposure.

Short term: Fairly rapid effects or Long term: Effects over a longer term).

Lethal: The test organism dies Sublethal: Some other effect is being measure.

A.2 Testing Aquatic or Marine Organisms A.2.1 Testing of soluble or miscible substances in water is relatively straight forward. The needed concentrations can be made up and the test water monitored through the test.


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A.2.2 Lubricating oil and hydraulic oil are both miscible in water and can be effectively maintained throughout the test waters with minimal agitation. Some substances are only partly miscible and an effective distribution can only be maintained through higher energy mixing. This level of agitation may in itself be harmful to the test organism. In these cases the substance should be considered immiscible (see below) A.2.3 Problems arise when the test substance is insoluble or immiscible. This is the case with Marine Diesel Oil (MDO) and Marine Gas Oil (MGO). When added to the test tank they float on the water surface and underlying test animals may receive only a minimal (or no) exposure. A.2.4 To test the toxicity of insoluble/ immiscible substances there are two options, the use of: Actual concentrations or Nominal concentrations. A.2.1 Actual Concentration Tests A.2.1.1 Tests using Actual concentrations measure the level of the test substance actually in the test water. This can be achieved by adding the test substance to the test tanks and providing mild to moderate agitation. For partly soluble or miscible substances some of the substance will enter the water and the concentrations can be measured. This may need the addition of a lot of the test substance to each tank. A.2.1.2 This method really is testing the toxicity of the water soluble fraction (WSF) of the test substance or the water miscible fraction (WMF). The WSF is comprised only of those components of the test substance that are soluble and so are not actually measuring the toxicity of the whole substance. A.2.1.3 The WSF of oils are generally more toxic than the whole oil. A.3.4 In some test methods the WSF is extracted from the oil and tested directly. It should be noted that the levels of WSF used in some tests are far higher than can be expected to occur below and oil slick and so the toxicity data is difficult to apply to the real world. A.2.1.5 Similarly WMF can be produced by high energy mixing of oil in water. WNF concentration can be produced far above what can be produced under natural conditions. A.2.2 Nominal Concentration Tests A.2.2.1 These testa measure concentration on the basis of the amount of test substance added to the test tanks. Depending on the test organism, this may result in only a nominal exposure and results may require unrealistic amounts of the substance to be added. A.2.2.2 As exposure is limited these tests invariably produce a high LC50, i.e. suggest a much lower toxicity than would result from an LD test.


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A.3 Application of Published Toxicity Data

A.3.1 Unless oil is discharged in solution or in seawater suspension the LC50s providedin SDS/MSDS are of little use in predicting environmental effects of oil spills.

A.3.2 Water soluble fractions of significance are rarely formed beneath surface slicksalthough some suspension of surface oil into the water column can occur.

A.3.3 Only toxicity data relating to a water miscible fraction has any relevance tointerpreting the effect of oil spilt onto marine waters. However, diesel oil suspensionsformed naturally below a slick will only form under significant mixing energy and thedroplets suspended into the water are much larger than those produced for laboratorytesting.

A.3.4 The effects of diesel oil (MDO and NGO) relate to the fact that they contact biota(mangroves, birds and intertidal invertebrates).

A.3.5 Lethal dose or Effective dose data can be useful for cases when wildlife doesingest diesel (e.g. birds preening oiled feathers) but this data is rarely available onSDS/MSDS.

A.3.6 Generally published data is of little ort no value in predicting the environmentaleffects of oil spills on either subsurface or surface organisms.


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ATTACHMENT B AUTHORS CV (SUMMARY)


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CURRICULUM VITAE: JOHN A. WARDROP

DATE OF BIRTH: 19/11/1953. NATIONALITY: British.

QUALIFICATIONS:

Bachelor of Science. University of Adelaide, 1978 (B.Sc). Graduate Diploma of Education, University of Adelaide, 1979 (Grad. Dip. Ed). Master of Environmental Studies, University of Adelaide, 1983 (M.Env.St). Civil Defence and Emergency Response Specialist (Russian Federation),

Department of Civil Defence, Emergency Response and Fire Safety for Sakhalin Region/ Emercom, 2003.

Certificate IV in Training and Assessment; TAE 40110. Certificate IV in Public Safety (Leadership) PUA41012. PROFESSIONAL ASSOCIATIONS Member and Committee Member, International Spill Control Organisation (ISCO). OVERSEAS EXPERIENCE: Australia, Canada, PR China, Hong Kong, India, Indonesia, Japan, Kazakhstan, S. Korea, Malaysia, New Zealand, Nigeria, Papua-Nuigini, Philippines, Russian Federation, Singapore, Thailand, U.S.A, SR Vietnam. SUMMARY OF EXPERIENCE: Specialist in areas include: emergency and oil spill response, planning, monitoring and training, environmental impact assessment, ecological assessments, shoreline assessment, cleanup and rehabilitation. Mr Wardrop is an Environmental Scientist with qualifications in marine, coastal and terrestrial ecology, environmental assessment and management. Areas of expertise include emergency response planning, training, development of emergency and OSR management systems and teams, evaluation of oil-impacted shorelines and communities and development of cleanup and restoration strategies. John has been involved in the response to a number of oil spills and has produced detailed emergency response plans, post spill monitoring plans and environmental management and remediation. These have encompassed onshore, offshore and coastal facilities and have been undertaken for industry, state and national governments. He has experience in building and training integrated response and management teams and has extensive experience in dealing with media and Government agencies both within Australia and overseas. John Wardrop has post graduate qualifications in education and extensive teaching experience. He has developed and presented a range of oil spill response related training courses.

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SUMMARY OF PROFESSIONAL EXPERIENCE: 2009 – Present, Australia: Managing Director, Seer Associates Pty. Ltd. 1982 - 2009, Australia: Manager, Wardrop Consulting. 2002-2007, Sakhalin Island, Russian Federation: Emergency and Oil Spill Response Manager

for Sakhalin Energy Investment Company. 1987 - 1996, Australia: Principal Environmental Scientist, Woodward-Clyde Pty Limited. 1986 - 1987, Australia.: Contract Environmental Consultant, Private And P F Manning And

Associates. 1979 - 1986, Australia: Mathematics-Science Teacher, South Australian Department Of

Education RELEVANT PROJECT EXPERIENCE (SUMMARY; COMPLETE LIST AVAILBLE ON REQUEST) RESPONSE SYSTEMS AND TEAM DEVELOPMENT

Development and training of community based monitoring teams, Niger Delta Nigeria (2013). Review of PTT response to the Rayon oil spill (2013) provision of advice to PTT GC, Thailand,

Gulf of Thailand spill, 2013/16. Development of Russian nationals-based emergency response and oil spill response

organisation for Sakhalin Energy Investment Company (SEIC). This included development of ER and OSR systems, organisation and strategies and also an implementation strategy for SEIC. All required Government and NGO negotiations were undertaken including Russian Federation, Sakhalin Oblast and IUCN (2003-2008).

Crib Point Terminal Pty. Ltd. (1992-1994): Hazard identification, risk assessment and assessment of environmental sensitivities of Western Port Bay. The project included public consultation, development of the coastal resource atlas and sensitivity indices, development of oil spill response zones, equipment capability assessment, and preparation of an OSCP.

OIL SPILL RESPONSE

Rayong Oil Spill, 2013, Thailand: Evaluation of marine and shoreline response and shoreline assessment.

Montara Well Release, August 2009, Timor Sea. PTTEPAA (2009-2011). Support to PTTEPAA and AMSA, August 2009-ongoing.

“Iron Baron” spill response, Tasmania, 1995 (on site July - December). Provision of shoreline cleanup advice, shoreline assessment (coordinator) and public/government liaison. This project involved on-site activities for 51/2 months.

“Era” Spill 1992, South Australia: Assessment of cleanup options for impacted mangroves. Participation in shoreline assessment and cleanup for a spill of heavy feedstock oil, Corio Bay

(1996). “Exxon Valdez” Spill, Alaska (1990 programme): Mr. Wardrop was involved in the

Bioremediation Programme, Biological Monitoring Programme, and Study of Coastal Oil Retention following the `Exxon Valdez' oil spill, in Alaska. This work involved site studies in Prince William Sound and the Gulf of Alaska.

RESPONSE PLANNING

Revision of Viva Energy OSCP Geelong Refinery (2017). Oil Spill Contingency Plan for Groote Eylandt Mining Company (GEMCO), Northern Territory

(2012/ 2016). Revision of PTT GC Oil Spill Contingency Plan, 2014.Provision of advice to PTT GC, Thailand,

Gulf of Thailand spill, 2013/16.


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Numerous Oil Spill Contingency Plans, reviews and revision for Government and Industry

clients (1988-presnt) including;. Revision of the PTTEPAA Oil Spill Contingency Plan (2010-11). Preparation of Onshore and offshore Pipeline Oil Spill Response Plans for Sakhalin Energy

Investment Company (SEIC). Also developed OSR Strategy and implementation strategy for SEIC and undertook all required Government negotiations (2003-2010).

Preparation of offshore Oil Spill Response Plans for Shell/CMOC exploration and development programmes (2006, 2007, 2008 and 2009), north Caspian Sea, Republic of Kazakhstan.

Preparation of Northern Territory Marine Oil Pollution Manual and Oil Spill Contingency Plan (2001).

Preparation of Victorian State Oil Spill Contingency Plan (2002) Preparation of Oil Spill Contingency Plans and Emergency Response Plans for Coastal Oil and

Gas Corporation exploration programmes in the Timor Sea and Ashmore-Cartier Island Territory (2002).

Preparation of Western Australian (National Plan) Marine Oil Pollution Emergency Management Plan (2000). Includes development of a Communications Sub-Plan, Occupational Health and Safety Sub-Plan and an Incident Control System.

DEVELOPMENT OF REGULATIONS, STANDARDS AND RESPONSE GUIDELINES

Preparation of Marine Pollution Planning Guidelines for the Republic of Kazakhstan National Plan (2013).

Preparation of Marine Pollution Planning Guidelines for the Australian National Plan, Australian Maritime Safety Authority (2012).

Assistance in development of Republic of Kazakhstan National oil spill response documentation and arrangements (2008).

Preparation of the Australian National Plan Chemical Agents Testing, Approvals and Monitoring protocols Australian Maritime Safety Authority (2011).

POST SPILL MONITORING

Assessment of Spill Impacts in Bodo Community Nigeria, Confidential Client, 2014-15. Assessment of Rayon Oil Spill Impacts Thailand, 2013. Contributor to development of a monitoring programme for offshore WA (Browse Basin,

through Sinclair Knight Mertz), 2012. Development and coordination of the Monitoring Plan for Montara Well Release, August 2009-

current, Timor Sea. Developed Post Spill Monitoring Handbook and Background Paper on Post Spill Monitoring for

Australian Maritime Safety Authority and Marine Safety New Zealand (2001-2002). Developed Post Spill Monitoring and Scientific Support Training courses for Great Barrier Reef

Marine Park Authority. Port Gawler, South Australia (1983-current): Mr. Wardrop designed and undertook an

extensive programme to study the effects of oil and dispersants on mangrove communities. This programme was undertaken in association with the S.A. Department of Fisheries and the Department of Environment and Planning and has been running for over fifteen years.

Port Adelaide River, South Australia (1985-1987): A programme to monitor the retention of spilt Bunker C fuel oil by intertidal muds. This study continued for two years.

“Era” Spill South Australia (1992-present): Design and undertaking investigation of residual oil and biological effects of the spill. Physical, biological and chemical studies were undertaken (4-year study report released in 1997).

Post spill assessment of oil impacted Melaleuca swamps, “Iron Baron” 1992. Author of position papers on monitoring and assessment of oil spills, Scientific Support

Coordinators/ Environmental Scientific Coordinators National Plan workshops (1985-96).


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RESPONSE PREPAREDNESS ASSESSMENTS AND AUDITS

Response preparedness (equipment and training) assessment of SEIC Phase 1 development, Sakhalin Island (2003) and Phase 2 development (2003-2007).

Response preparedness audit for Mobil Refinery, Altona, Victoria Australia (2002). Review of equipment capability and requirements for Malaysian National Response Centre;

Petroleum Industry of Malaysia Mutual Assistance Group (PIMMAG), (1993). Review of corporate risk and regional spill response capability in Western Port Bay, Victoria.

(BHP Bass Strait Asset, 1997). Prepared, coordinated and participated in Exercise “George Bass”, Victoria 1996. Contributed to the National Plan Training Review (for Capricorn Environmental Consultants). Review of Victorian spill preparedness and cost implications of port privatisation (1996) SHORELINE RESPONSE PLANS AND FIELD (OPERATIONAL) HANDBOOKS

Assessment of spill response Bodo Community, Nigeria (2014) Preparation of handbooks in support of SEER and National Plan (Australia) training course,

2013-18. Preparation of OSR Handbooks for all SEIC facilities on Sakhalin Island (2006-2010). Preparation of a Shoreline Response Handbook, management system and Shoreline

Coordinators Resource Kit for Corio Bay and Outer Harbour. Shell Geelong Refinery, Victoria (2000 and 2001).

Shoreline Response Handbook and management system for Northern Port Phillip Bay, for Mobil Altona (1998, updated 2002).

Shoreline Response Handbook and management system for western Western Port Bay, for Department of Natural Resources and Environment (1999).

TRAINING, EXERCISES & WORKSHOPS:

John Wardrop has developed and contributed to the development of numerous oil spill response and environmental courses and has wide experience in the training of students with diverse nationalities, abilities and levels of experience. Indicative training experience is provided below: Development and presentation of SEER OSR training courses, 1999-2020. Development and presentation of Australian National Plan Incident Management Team (IMT)

Course, 2011-2014. Development of National Plan training courses for the Australian Maritime Safety Authority,

2011-12. Presentation of oil spill training to Philippines Coast Guard (Australian Dept. Foreign Affairs and

Trade and AMSA), 2012. Presentation of oil spill training to Vietnam maritime services (Australian Dept. Foreign Affairs

and Trade and AMSA), 2012. Preparation and presentation of shoreline response planning and management courses for

NSW Maritime and Australian Marine safety Authority (AMSA), Australia (2008 - present). Preparation and presentation of shoreline response planning and management courses for

Marine Safety Victoria, Australia (1997-present). Australia Marine Oil Spill Centre (AMOSC), Geelong (1994 -2003): Presentation of lectures at

the Australian Marine Oil Spill Centre, Geelong, Victoria. Lectures cover Environmental issues, Shoreline Cleanup, Chemical Dispersants and Inland Spills. These have been presented in all states of Australia.

IMO On Scene Commanders Course, Vung Tau, Vietnam (August, 1999) for SFT Norway (Norwegian aid programme).


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Invited lectures and presentations at workshops and conferences in Japan, Malaysia, Australia,

Indonesia, Vietnam and Philippines. RESEARCH AND REVIEWS A number of clients have commissioned investigations of the chemical or physical properties of oils, with a view to better understanding the potential for ecological harm or the efficiency of various response management strategies. Generally, these reports are confidential. Refer to publications list. PUBLICATIONS: Journal and Other Articles Black, K.P.; Brand, G.W.; Grynberg, H.; Gwyther, D.; Hammond, L.S.; Mourtikas, S.;

Richardson, B.J. and J.A. Wardrop, (1994b) Production Facilities. In: Environmental Implications of offshore oil and gas development in Australia - the findings of an independent scientific review, Swan, J.M., Neff, J.M. and Young, P.C. (Eds), Australian Petroleum Exploration Association, Sydney, pp. 209-407.

Bogdanovsky A.A, J. A. Wardrop, I. Kochergin, S. Pokrashenko, I. Arshinov and S. Rybalko, 2005. Progress in Oil Spill Risk Assessment for Sakhalin Shelf Conditions. In Proceedings of Pisces XIV.

Bogdanovsky A.A., I.E. Kochergin, I,A Arshinov, S.I Rybalko, V.P. Tunegolovets, N.S. Kupera, S.A. Pokrashenko and J.A Wardrop, 2004. New Comprehensive Oil Spill Modelling for Potential Sources Near Sakhalin Island. In PISCES XIII Poster GP-1962.

Bogdanovsky A.A., I.E. Kochergin, S.A. Pokrashenko, J. Wardrop, O.I. Zilberstain, I.A. Arshinov, S.I. Rybalko, N.S. Kupera, 2006. Stochastic and Diagnostic Oil Spill Modelling in Aniva Bay and Adjacent Areas. Applied oceanography.

Bogdanovsky A.A., J. Wardrop, I.E. Kochergin, S.A. Pokrashenko, I.A. Arshinov, S.I. Rybalko, 2006. Progress in Oil Spill Risk Assessment for Sakhalin Shelf Conditions Applied oceanography. In PICES XIV.

Castle R.W., E.H. Owens, J.D. Sartor and J.A. Wardrop, 1991. Oil Spill Contingency Planning in Tropical Areas. In Proceedings SPE Conference Perth, Western Australia. Paper SPE 23020.

Hancock S., H. Grynberg, P Lindon and J.A. Wardrop, 1992. Environmental Issues Deriving from the Energy Winning Activities in the Gippsland Basin. In Proceedings of the Gippsland Basin Symposium: 211 - 215.

Jamieson, D, D and J. A Wardrop, 1992. Risk Assessment and Analysis of Oil Pollution of the Seas of New Zealand. Search And Discovery Article No 91015©1992 AAPG International Conference, Sydney, N.S.W., Australia, August 2-5, 1992; Article 91015©1992 AAPG Bulletin. Vol. 76.

Manning P.F., and J.A. Wardrop, 1986. The Development of a Scientifically Based Oil Spill Contingency Plan for Port Bonython South Australia. In Proceedings National Conference on Coastal Management: 425 – 429.

Pokrashenko, S and J.A Wardrop, 2006. Oil Spill Response Challenges for the Sakhalin II Project. In Proceedings of the Oil and Gas Developments in Arctic Regions 2nd Annual Conference, 26th -27th June 2006, Stavanger.

Stevens, L and J.A Wardrop, 2001. Oil Spill Monitoring Handbook. In Proceedings of the International Oil Spill Conference, USA.

Smith J.P., J.A. Wardrop and A. Kilburn, 1994a. Developing Effective Environmental Oil Spill Management for Remote Locations. In Proceedings SPE Conference, Melbourne. Paper 28768.


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Smith J.P., J.A. Wardrop and M.R. Seignior, 1994b. Testing of Highly Paraffinic Crude Oils for

Toxicological Effect and Chemical Dispersability. In Proceedings 26th Offshore Technology Conference, Houston, Texas 2-5 May 1994: 287 - 300.

Stevens, L and J. Wardrop. 2005. Oil Spill Monitoring Handbook. In Proceedings of the International Oil Spill Conference; Miami Beach, Florida USA; 937 - 941

Wardrop J.A. 1987. The Effects of Oils and Dispersants on Mangroves: A Review and Bibliography. Centre for Environmental Studies. University of Adelaide Occasional Paper No. 2.

Wardrop J.A. 1992. Chemical Dispersant Use in Oil Spill Management: Kill or Cure? The Controversy Persists. In Proceedings 1992 Society of Petroleum Engineers Conference, Perth; Paper SPE 22999.

Wardrop J.A. 1993. The Effects of Oil and Dispersants on Mangroves. In Proceedings Port of Melbourne Authority Dispersants Workshop. Hastings, Victoria.

Wardrop, J.A. 1997. Post Spill Monitoring and Assessment. In Proceedings Scientific Support Coordinators Workshop, Darwin, 22nd - 27th September, 1997.

Wardrop, J. A. 1997. Post Spill Monitoring: A Brief Retrospective. Paper presented to the Sixth Scientific Support Coordinators Workshop. Darwin, NT.

Wardrop, J.A. 2005. Oil Spill and Transport in Northern Climates: Technology, Regulation, Preparedness. A Case Study: Cristoforo Colombo Incident: Sakhalin Energy Investment Company Overview. Petroleum Association of Japan Conference, Tokyo, Japan.

Wardrop, J.A. 2010. Montara Well Release, August 2009. Monitoring Operations: Sampling and Longer Term. Paper presented to Spillcon 2010, Melbourne, Victoria, Australia

Wardrop, J. and D. Ball, 2000. Development of a Recommended Shoreline Classification System for the Australian Oil Spill Response Atlas. Marine and Freshwater Resources Institute Report

Wardrop J.A., A.J. Butler and J. Johnson, 1987. A Field Study of the Toxicity of Two Oils and a Dispersant to the Mangrove Avicennia Marina. Marine Biology 96:151-16.

Wardrop J.A., S. Simonova, 2007. Contingency Planning for Challenging Environments. Paper presented to Spillcon 2007, Perth, Western Australia.

Wardrop J.A., J.P. Smith, D. Palmer, M. Seignior, K. Fucik, M. Giroletti and J. Leeder, 1994. The Testing Assessment and Use of Dispersants: A Systematic Approach. In Proceedings SPE Conference, Melbourne, Victoria, Australia, November. Paper SPE 28770.

Wardrop J.A. and B. Wagstaff, (In Press). The Penetration and Persistence of Bunker C Fuel Oil in Mangrove Sediments.

Wardrop, J A and B. Wagstaff, 1995 . Damage Assessment and Post Spill Monitoring. In Proceedings of the Fifth Scientific Support Coordinators Workshop. Cronulla, NSW.

Wardrop J.A., B. Wagstaff and E.C. Wayment, 1994. Oil Spill Documentation and Assessment: The Need for a Systematic and Planned Approach. In Proceedings Oil Spill Response Conference1994. Kuala Lumpur, Malaysia.

Wardrop, J A and B Wagstaff, 1996. Post Spill Environmental Monitoring and Assessment. In Proceedings of Spillcon ‘96. Melbourne, Australia.

Government Reports and Other Publications Assessment of Oiled Shoreline: A Simplified Approach (1999, 2nd Edition April 2002, 3rd Edition

December 2010). ISBN 0-646-37636-5. The Effects of Oils and Dispersants on Mangroves: a Review and Bibliography (1987)

University of Adelaide, Department of Environmental Studies, Occasional Paper No.2. ISBN: 0-86396-057-X / 086396057X, 978086396057

The Effect of Oil, Dispersants and Response on Mangroves; A Review and Bibliography (2002, 2nd Edition 2011, 3rd Edition 2020 in press).


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The Use of Dispersants Inshore and on Shorelines; A Review of the Available Data (1989, 2nd

Edition 2003). Damage Assessment and Post Spill Monitoring: A Review. Shoreline Response Handbook. ISBN: 978-0-9805355-0-1 (11th Edition inpress). Health and Safety Handbook for Oil Spill Response. Australasian Edition ISBN 978-0-

9805355-8-7. (under review and revison) Oil Spill Response Monitoring Handbook. ISBN: 978-0-9805355-4-9. Western Port Oil Spill Shoreline Response Manual. Marine and Freshwater Resources

Institute Report, Victoria, Australia. Wardrop, J.A and B. Wagstaff, 1985. Port Adelaide River Oil Spill: May 1985; Monitoring

Programme Final Report. Dept Environment and Planning, Adelaide, South Australia. Wardrop, J A, P. Pfennig, B. Wagstaff, R. Connolly and J. Leeder, 1997. The Distribution and

Persistence of Petroleum Hydrocarbons in Mangrove Swamps Impacted by the “Era” oil Spill (September, 1992): Final Phase I Report. Report to the Environment Protection Authority of South Australia. ISBN: 0-646-34334-3 / 0646343343, 9780646343341.

Wardrop, J A., B. Wagstaff, R. Connolly and J. Leeder, 1994. The Distribution and Persistence of Petroleum Hydrocarbons in Mangrove Swamps Impacted by the “Era” oil Spill (September, 1992). Report to the Environment Protection Council of South Australia. ISBN: 7308-2705-4/ 0730827054, 9780730827054.

Australian Maritime Safety Authority, 2009. Montara Well Release Operational Monitoring Study O2 Monitoring of Oil Character, Fate and Effects: Report 01 Oil Character. AMSA-02-01P.

Australian Maritime Safety Authority, 2009. Montara Well Release Operational Monitoring Study O2 Monitoring of Oil Character, Fate and Effects: Report 02 Water Quality. AMSA-02-02P.

Australian Maritime Safety Authority, 2009. Montara Well Release Operational Monitoring Study O2 Monitoring of Oil Character, Fate and Effects: Report 03 Dispersant Treated Oil Distribution. AMSA-02-03P.

Australian Maritime Safety Authority, 2009. Montara Well Release Operational Monitoring Study O2 Monitoring of Oil Character, Fate and Effects: Report 04 Oil Character, Behaviour, Fate and Weathering. AMSA-02-04P.

Australian Maritime Safety Authority, 2009. Montara Well Release Operational Monitoring Study O2 Monitoring of Oil Character, Fate and Effects: Report 05 Potential Shoreline Impact: Presence and Character of OIl. AMSA-02-05P.


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ATTACHMENT C OCCASIONAL DISCHARGES

C1 Overview

C1.1 The EES identifies two discharges that are to be routine:

1. Firewater Test 2. Hull and propeller cleaning discharges

C2 Seawater Discharges from Firewall Testing

C2.1 The EES notes the discharge of seawater from regular testing of fire systems.

C2.2 Volumes estimated are given as 1,550m3 of seawater discharged over a 1

hour period every two weeks EES Tables 4-3, 6-1 and 6-19.

C2.3 This discharge has received little of no further consideration in the EES.

C3 Discharges from Hull and Propeller Cleaning

C3.1 Nature of the Discharge

C3.1.1 The EES notes that regular de-fouling of the FSRU hull and propeller will be undertaken although no details are provided as to how this would be done.

C3.1.2 It is not stated whether cleaning agents will be used but presumably the

operation will be based on high pressure seawater cleaning. It is stated in the EES that debris will be produced by the process but provides no indication of what this debris may consist of.

C3.1.3 The EES should state clearly what cleaning methods are to be used and

whether loss of anti-fouling materials to the waters of Westernport is possible. If possible then volumes (or concentrations) should be calculated.

C3.1.4 The EES provides no indication as to what antifouling coatings will be applied

to the FSRU or whether these will be removed during the cleaning process and lost as ‘debris’

C3.1.5 The EES should state clearly what anti-fouling agents will be used on the

FSRU.

C3.2 Discharge Management

C3.2.1 The EES states that:

C3.2.2 “ Large cleaning debris would be taken to shore for disposal. ” (EES Technical A, Appendix A Section 7.9.4).


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C3.3.3 It is assumed therefore that fine debris will not be collected or disposed of. The EES also concedes that:

C3..3.4 “ … strong tidal currents at Crib Point may affect the efficiency of hull cleaning and collection of removed biological debris. ” (EES Technical

Appendix A Section 7.9.4).

C3.3.5 Marine discharges for hull and propeller cleaning are to be mitigated initially as per the Port of Hastings Operating Handbook (MM-ME05). However the Handbook mentions hull and propeller cleaning only once:

C3.3.6 “ No hull cleaning or propeller polishing is allowed in Western Port and no substance, other than approved ballast water, is to be discharged into Port

Waters. ” PoH Operating Handbook Section 5.20(e).

C3.3.7 No mention is made of a permit system for these activities and the EES does not state how these activities are to planned, approved managed or monitored.

C3.3.8 The EES must address the management of hull and propeller cleaning activities.

C.3.4 Risk Assessment

C3.4.1 Despite the lack of any details regarding the materials that could be released by this process, identification of the area that could be affected or the organisms that could be affected and the absence of any analysis the EES concludes:

C3.4.2 “ The likelihood for release of contaminants during hull and propeller cleaning operations is ranked as unlikely. ” (Technical Appendix A Section 7.9.4).

C3.4.3 and

C3.3.5 “ Any releases are likely to be small to negligible; the consequence is ranked as minor. ” (Technical Appendix A Section 7.9.4).

C3.3.6 The EES notes that a permit for this activity is required from the Port of Hastings. Hopefully some better assessment of potential environmental effects will be presented prior to the granting of such a permit.

C3.3.8 An assessment of the potential effects of FSRU maintenance activities should be undertaken (see Tables C1 and C2).


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Table C1 Summary of Identified Natural Resources and Risk Assessments

(Based on EES Section 6 Table 6-11 and Technical Report A)

Risk (EES) Assessment and Analysis Discharge Receptors

Initial Residual Risk ID EES Ref. Firewater runoff during testing

None identified None None None


Hull and prop cleaning runoff

See Note 1 Low Low ME44


1 The EES does not list the types of contaminants that may be released by hull or propeller cleaning

Table C2 Summary of Proposed Mitigation Strategies as Set out in the EES

Mitigation Measure (Table 6-23) Discharge or Activity Risk ID (Table 6-11)

Initial Additional Hull and prop cleaning ME44 MM-ME05 MM-ME06 Firewall runoff during testing Not listed None None


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ATTACHMENT D LETTER OF BRIEF


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