Fletcher Finucane Subsea Construction Phase Environment Plan … · 2012-12-24 · Subsea 7 Subsea...

Fletcher Finucane Subsea Construction Phase Environment Plan Summary

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TABLE OF CONTENTS

1 INTRODUCTION ......................................................................................................... 3

2 ABBREVIATIONS ....................................................................................................... 3

3 PROJECT LOCATION AND CO-ORDINATES OF THE ACTIVITY ........................... 5

4 DESCRIPTION OF THE ACTION ............................................................................... 8

5 DESCRIPTION OF RECEIVING ENVIRONMENT .................................................... 12

5.1 Physical Environment .......................................................................................................................... 12

5.2 Cultural Environment ........................................................................................................................... 13

5.2.1 Archaeological Heritage ......................................................................................................... 13

5.2.2 Maritime Heritage ................................................................................................................... 13

5.3 Sensitive Areas ..................................................................................................................................... 13

5.4 Socio-economic Environment ............................................................................................................. 14

5.4.1 Settlements ............................................................................................................................ 14

5.4.2 Commercial Fisheries ............................................................................................................ 14

5.4.3 Shipping ................................................................................................................................. 15

5.4.4 Recreational activities ............................................................................................................ 15

5.4.5 Petroleum exploration ............................................................................................................ 15

5.5 Biological Environment ........................................................................................................................ 15

Benthic Environment .............................................................................................................................. 15

Pelagic Environment .............................................................................................................................. 15

6 MAJOR ENVIRONMENTAL HAZARDS AND CONTROLS ..................................... 16

7 MANAGEMENT APPROACH ................................................................................... 23

8 STAKEHOLDER CONSULTATION .......................................................................... 23

9 CONTACT DETAILS ................................................................................................. 25



1 INTRODUCTION

Santos Ltd (Santos) is developing the Fletcher and Finucane South oil fields, located in exploration permit WA-191-P on Western Australia’s North West Shelf (NWS) (Figure 3.1), as operator on behalf of its joint venture partners.

The Fletcher Finucane Development consists of a subsea infrastructure development tied-back to the existing Mutineer manifold where production will be commingled with Mutineer production and then flow through the existing Mutineer flowline and riser to the existing MODEC Venture 11 (MV11) Floating Production Storage and Offloading unit (FPSO).

In accordance with Regulation 4(1) of the Offshore Petroleum and Greenhouse Gas Storage (Environment) Regulations 2009 (OPGGS (Environment) Regulations), the Environment Plan (EP) applies to a defined “Petroleum activity”.

The “petroleum activity” for the Fletcher Finucane Development construction campaign is defined as:

the subsea installation of flowlines, manifolds and associated equipment by the DSV Rockwater 2 within the project area (WA-191-P , WA-26-L and WA-27-L) that connects the Fletcher-5, Finucane South-2H and Finucane South-3H development wells to the existing Mutineer infrastructure for production through the existing MV-11 FPSO.

2 ABBREVIATIONS

AHS Australian Hydrographic Service

AIS Automatic Identification System (a navigation system for

locating, identifying and tracking marine vessels)

ALARP as low as reasonably practicable

AMOSC Australian Marine Oil Spill Centre

AMSA Australian Maritime Safety Authority

APASA Asia-Pacific Applied Science Associates

AQIS Australian Quarantine Inspection Service

AS /NZ ISO Australian / New Zealand Standards International

Standards Organisation

Bbl Barrels

DAFF Department of Agriculture, Fisheries and Forestry

DEC Department of Environment and Conservation

DEWHA Department of Environment, Water, Heritage and the Arts

(succeeded by DSEWPC, below)

DSEWPC

DMP

Department of Sustainability, Environment, Water,

Populations and Communities

Department of Mines and Petroleum



DoF Department of Fisheries

DoT Department of Transport

DP Dynamic positioning

DSEWPC Commonwealth Department of Sustainability, Environment,

Water, Population and Communities

DSV Diving Support Vessel

EHS Environment Health Safety

EHSMS Environment Health Safety Management Standard

EHU Electro-Hydraulic Umbilical

EP Environment Plan

EPBC Act

EPU

Environment Protection and Biodiversity Conservation Act

1999

Electric Power Umbilicals

FAT factory acceptance testing

FPSO Floating Production Storage and Offloading unit

HAZID Hazard Identification workshop

HLV Heavy Lift Vessel

HRV Hyperbaric Rescue Vessel

IMS invasive marine species

JHA Job Hazard Analysis

km kilometre

MARPOL International Convention for the Prevention of Pollution

from Ships

MDO Marine Diesel Oil

MPFM

MPP

Multi-phase flow meter

Multi-phase pump

MPRA Marine Parks and Reserves Authority

MV11 MODEC Venture 11

NES national environmental significance

nm Nautical Miles

NOAA National Oceanic and Atmospheric Administration

NOPSEMA National Offshore Petroleum Safety and Environmental

Management Authority

NWS North West Shelf

OCNS Offshore Chemical Notification Scheme

OPGGS (Environment) Offshore Petroleum and Greenhouse Gas Storage



Regulations (Environment) Regulations 2009

OPGGS Act Offshore Petroleum and Greenhouse Gas Storage Act

2006

OSCP Oil Spill Contingency Plan

OSPAR Oslo Paris Convention (Convention for the Protection of

the Marine Environment of the North-East Atlantic)

OWS Oily water separator

PFW

PLEM

Produced formation water

Pipeline End Manifold

PMST Protected Matters Search Tool

PMS Planned Maintenance System

RAMSAR Convention on Wetlands of International Importance

especially waterfowl habitat 1971

RCC Rescue Coordination Centre

ROV remote operated vehicle

Santos Santos Ltd

SOPEP Ship Oil Pollution Emergency Plan

STP Sewage Treatment Plant

Subsea 7 Subsea 7 Australia Contracting Pty Ltd

Te Tonnes

TM Master Subsea 7 Rockwater 2’s Planned Maintenance system

ZPI Zone of Potential Impact

3 PROJECT LOCATION AND CO-ORDINATES OF THE ACTIVITY

Project Area Definition

All Fletcher Finucane Development installation activities will be confined to a discrete Project Area (‘envelope’) within Petroleum Exploration Permit WA-191-P and Production Licences WA-26-L and WA-27-L.

The Project Area is defined by the geographic coordinates in Table 3.1 and as illustrated in Figure 3.1.

While the DSV Rockwater 2 is in the Project Area, it is undertaking a petroleum activity as defined in Section 1.



Table 3.1 Geographic location of the Fletcher Finucane Development Project Area envelope

Latitude Longitude

degrees minutes seconds degrees minutes seconds

Northeast corner (A) 19 13 38.6 116 49 09.2

Southeast corner (B) 19 19 36.4 116 46 17.5

Southwest corner (C) 19 17 08.8 116 35 09.5

Northwest corner (D) 19 14 26.5 116 38 01.2

Figure 3.1 shows the location of the proposed Fletcher Finucane Development in the context of petroleum permits and infrastructure on the NWS.

Geographic coordinates for various proposed and existing infrastructure is listed in Table 3.2.

Table 3.2 Geographic location of the proposed and existing Fletcher Finucane Development infrastructure

Latitude Longitude

Proposed

Fletcher-5H well 19 14 46.2 116 47 43.9

Fletcher manifold 19 14 43.8 116 47 43.9

Finucane South-2H well 19 17 34.1 116 45 49.4

Finucane South-3H well 19 17 35.7 116 45 50.5

Finucane South manifold 19 18 17.3 116 45 32.9

Existing

Mutineer manifold 19 15 32.8 116 38 16.3

Exeter manifold 19 18 35.4 116 33 41.1

MV11 FPSO turret 19 16 33.4 116 36 45.5



Figure 3.1 Location of the proposed Fletcher Finucane Development

A – Project Area



4 DESCRIPTION OF THE ACTION

Overview of the Fletcher Finucane Development project

The MODEC Venture 11 FPSO and the associated Mutineer – Exeter subsea infrastructure, operated by Santos, has been in production since March 2005. The facility is currently producing around 8,000 barrels (bbl) of oil a day, with a production capacity of 140,000 bbl/day of fluids and a storage capacity of 930,000 bbl.

The new Fletcher Finucane wells will add an expected 65,000 bbl/day to current production and extend the field life of the FPSO by 4-5 years. First oil is planned for the second quarter (Q2) of 2013.

Installation of Fletcher Finucane Development Infrastructure

The subsea construction phase to which this EP Summary applies is the installation of the new Fletcher Finucane Development infrastructure (including flowlines, umbilicals and manifolds) by the DSV Rockwater 2.

Figure 4.2 is a schematic of the proposed subsea development, including the existing Mutineer – Exeter subsea infrastructure, the FPSO and the proposed facilities for the Fletcher Finucane Development.

All in-field installation activities within the Project Area will be performed by the DSV Rockwater 2 (Figure 4.1) operated by Subsea 7 Pty Ltd.

The DSV Rockwater 2 features a 16-man single bell saturation diving system rated to 300m.

The vessel is classified as a Class II dynamic positioning (DP) vessel, meaning it can remain on location without anchoring. The vessel has had a Kenz crane installed to enable the vessel to expand its capabilities to include cable and pipe laying and remote operated vehicle (ROV) support.

The heave compensated 200 Te offshore Kenz crane has a 300 Te harbour lifting capacity and a 200 Te offshore lifting capacity.

This vessel has proven offshore installation capabilities in Australia and with Santos. Santos used Subsea 7 and the DSV Rockwater 2 in 2004 to install the MV11 FPSO moorings, risers, umbilicals and perform the subsea tie-ins to the production wells. Again in 2009/10, Santos used Subsea 7 and the DSV Rockwater 2 to complete the Henry gas field subsea tie-back to the existing Casino field subsea infrastructure in Victoria’s Otway Basin.



Figure 4.1 DSV Rockwater 2

The following is a basic outline of the installation sequence and methodology that will be employed. It is noted that the proposed sequence may be subject to variation at the discretion of the Construction Manager and Vessel Master, to account for environmental conditions (i.e., weather, ocean currents, etc.) at the time. The primary installation activities and methodology will remain as described below:

On arrival in field location, the DSV Rockwater 2 will conduct a field survey using a remotely operated vehicle (ROV).

Installation of the manifolds at the Finucane and Fletcher locations.

Installation of the pipeline end manifold (PLEM) at the Mutineer location.

Conduct metrology to allow the accurate dimensioning for the fabrication of the rigid

tie in spools for connecting the manifolds to the wells at Fletcher and Finucane, and

the PLEM to the existing Mutineer manifold.

Installation of the flexible well service flowlines from Mutineer to Finucane and then

Fletcher to Finucane.

Installation of the flexible production flowlines between Mutineer and Finucane, and

Mutineer and Fletcher.

Installation of the EPU and EHU.


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The subsequent stages of the installation campaign require diver support. Prior to commencement of the diver activity, a number of preparatory activities will be carried out from the FPSO to ensure the adequate isolation (production, well service and Exeter EPU) as well as flushing of existing systems prior to disconnection of any systems at the Mutineer manifold. The diver-assisted activities include:

Recover and relay the Exeter EPU-2.

Complete tie-ins of flowlines, well service lines, rigid spools and flying leads at each

of the Finucane and Fletcher locations.

Complete tie-ins of flowlines, well service lines, rigid spools and flying leads and

replacement of the existing MPFMs at the Mutineer location.

On completion of the tie-ins, the following pre-commissioning and cold commissioning activities will be carried out:

Conduct leak tests of installed equipment (production and well service flow paths).

Assist in visual observation and inspection during cold commissioning activities (i.e.,

confirmation of valve status, positions during function testing).

Conduct as-built survey.

On completion of the as-built survey and cold commissioning assistance, the DSV Rockwater 2 will demobilise from the field, and the project activity is complete.


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Figure 4.2 Schematic of the proposed Fletcher Finucane Development tied into the existing Mutineer – Exeter infrastructure


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5 DESCRIPTION OF RECEIVING ENVIRONMENT

The physical, biological and cultural and socio-economic environment in and around the Project Area, as defined in Section 3, and the North West Shelf (NWS) ‘region’ in general are described in this chapter. The region can be seen in Figure 5.1.

Figure 5.1 North West Shelf Region

5.1 Physical Environment

The physical environment at the Project Area is summarised as:

The highest mean monthly ambient temperature is 37.7°C in March, with the lowest

mean monthly ambient temperature being 23.9°C in July.

The surface waters of the NWS Province are tropical year-round, with summer

temperatures averaging 26ºC.

Most rainfall in the region occurs during the summer period (the wet season),

usually associated with either monsoonal thunderstorms or tropical cyclones. The

wet season is generally from January to July, with most falls occurring during the

first half of the wet season (January to March). The average annual rainfall at

Karratha Aerodrome is 290 mm.


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The wind data indicates that the winds were predominantly from the south-west

during the summer and transitional spring months, and most frequently from the

east to southeast during the winter period.

Tropical cyclones originate from the eastern Indian Ocean, and the Timor and

Arafura Seas during the summer months of November to April. Since recordings

began in 1960/61, tropical cyclones have approached the area from the northwest

through to east, with the most frequent directions being from the north (34%) and

east (36%).

Ocean currents on the NWS are dominated by the southward-flowing warm surface

Indonesian Throughflow, which flows from the tropics to the waters of southwest

Western Australia, with the Leeuwin Current a distinct current south of North West

Cape, near Exmouth.

5.2 Cultural Environment

5.2.1 Archaeological Heritage

The water depth of the Project Area means it is highly unlikely that there are any Aboriginal or non-Aboriginal archaeological sites within the Project Area (i.e., evidence of past occupation). The National Heritage List, which includes Indigenous places of outstanding heritage values, does not list any sites in or around the Project Area.

5.2.2 Maritime Heritage

The geophysical survey conducted in August 2011 for the Fletcher-Finucane Development (Neptune, 2011) did not find any shipwrecks within the footprint of the Project Area.

There are no historic shipwreck protected zones in or around the Project Area (DSEWPC, 2012).

5.3 Sensitive Areas

There are 13 new Commonwealth Marine Reserves proposed for the North West Marine Region. The Project Area does not impact any of these reserves. The closest proposed marine reserve is ‘Dampier Commonwealth Marine Reserve’ which is located 116 km south of the Project Area.

There are four World Heritage Sites located in Western Australia, with none of these located in or adjacent to the Project Area.

There are 20 Commonwealth Heritage Sites located in Western Australia, with none of these located in or adjacent to the Project Area.

There are 13 National Heritage Places located in Western Australia, with none of these located in or adjacent to the Project Area.


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There are 12 Wetlands of International Significance (Ramsar wetlands) in Western Australia, with none of these located in or adjacent to the Project Area.

The Dampier Archipelago (consisting of 42 islands, islets and rocks within a 45 km radius of Dampier) is proposed as the Dampier Archipelago Marine Park (DAMP) under Western Australia’s Conservation and Land Management Act 1984. The Project Area does not impact the Dampier Archipelago.

Glomar Shoal is a key ecological feature of the region because of its integrity values (high productivity) and biodiversity values (aggregations of marine life), which apply to both its benthic and pelagic habitats.

Glomar Shoal is a submerged seabed feature located approximately 150 km north of Dampier, and 25 km (13 nm) south of the project area within the ZPI, at depths ranging between 33 and 77 metres (Falkner et al. 2009 in DSEWPC, 2011). The shoal consists of a high percentage of marine-derived sediments with high carbonate content and gravels of weathered coralline algae and shells (McLoughlin & Young 1985, in DSEWPC, 2011). While much of the biodiversity associated with the Glomar Shoal has not been studied, it is known to be an important area for a number of commercial and recreational fish species such as rankin cod, brown-striped snapper, red emperor, crimson snapper, bream and yellow-spotted triggerfish (Fletcher & Santoro 2010 in DSEWPC, 2011; DEWHA, 2008). These species have recorded high catch rates associated with the Glomar Shoal, indicating that it is likely to be an area of high productivity.

5.4 Socio-economic Environment

5.4.1 Settlements

The Project Area is located approximately 150 km/81 nm north-northwest of Dampier (in the Shire of Roebourne).

5.4.2 Commercial Fisheries

The North West Slope Trawl Fishery was the only Commonwealth-managed fishery with logbook data for the region from 2008-2010, with only periodic activity through the year concentrated from January to mid-March and June-July (when the nearby Northern Prawn Fishery is not operational). Westmore and Sharkbay Seafoods, who operate in the North West Slope Trawl Fishery, has stated that the project will not impact their operations as their trawl operates beyond the 200 m depth contour.

Western Australian fisheries are managed by the Department of Fisheries (DoF). The Project Area falls into the North Coast fishing bioregion. The DoF has advised Santos that only the Pilbara Fish Trawl Fishery has recorded fishing effort within the Project Area in the last five years.

The fishing industry has been consulted, as described in Section 8, in particular through the Australian Fisheries Management Authority, the Commonwealth Fisheries Association Western Australian Fishing Industry Council as well as with individual organisations. No concerns were raised during the consultation process.


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5.4.3 Shipping

The ports of northwest Australia (Onslow, Dampier, Cape Lambert, Port Hedland and Broome) handle large tonnages of iron ore and petroleum exports, resulting in very busy shipping routes through the area. The closest port to the Project Area is Dampier.

The Maritime Standards Division of the Australian Maritime Safety Authority has informed Santos, through the consultation process, that the locations of the new wells is approximately 5nm west of the Dampier Shipping Fairway. Significant vessel traffic uses this fairway travelling to or from the Port of Dampier, however the traffic is concentrated in this area and Project activities are not anticipated to impact on the traffic using the fairway.

5.4.4 Recreational activities

Recreational fisheries are managed by DoF. DoF (2011) states that recreational fishing occurs mostly in State waters adjacent to populated coastal areas.

RecFish West indicates that the project area is not likely to be visited by recreational fishers and charter boats, with the closest area of interest being the Glomar Shoals, located 25 km (13 nm) south of the project area.

5.4.5 Petroleum exploration

The NWS is Australia’s most prolific oil and gas production area, largely responsible for Western Australia accounting for 77% of the country’s oil and condensate production and 55% of the country’s gas production in 2008 (APPEA, 2011).

5.5 Biological Environment

Benthic Environment

Given the depth of water and nature of the seabed, few significant benthic resources are expected to be located across the Project Area, in line with the featureless sandy seabed observed during surveys of the area. The depth of water limits the occurrence of algae, seagrass, corals and some fish and reptile species, while the absence of hard substrates prevents many forms of sessile fauna from colonising the seabed (e.g., molluscs). Sandy substrates of the North West Shelf (NWS) in this region are considered to support a low density of benthic communities of bryozoans, molluscs and echinoids, with sponge communities found only in areas containing hard substrates.

Pelagic Environment

The offshore waters of the NWS are oligotrophic (low in nutrients) and planktonic abundances are likely to be low. The NWS supports a diverse assemblage of fish, particularly in shallow water near the mainland and around islands. Most fish have tropical distributions and are well distributed throughout the Indo-West Pacific region. Some of the deep-water (100-200 m depth range) fish and school species that occur in the Project Area are deep goatfish (Mullidae family), deep lizardfish (Synodontidae family), ponyfish (Leiognathidae family), deep threadfin bream (Nemipterus genus), trevally (Caranx family), billfish (sailfish, marlin and swordfish) and tuna (species of the Thunnus, Katsuwonis and Euthynnus genera).


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Five species of marine turtles may occur within the Project Area according to the EPBC Act PMST. Four of these species, the green, hawksbill, flatback, and loggerhead turtles (from the family Cheloniidae) are known to have major breeding rookeries along the Pilbara coast. The breeding areas are outside the Project Area and outside the zone of potential impact from the Project.

Twenty (20) whale and dolphin species (cetaceans) may use the habitat of the Project Area, some being seasonal visitors while others occur at low densities all year round. The peak migratory periods for humpback whales around the Dampier Archipelago are July and August for the northbound leg and August/September for the southbound leg. The migratory path is the continental shelf of Australia.

The Project Area is located on the estimated northern edge of the northern and southern migration paths. The activity is scheduled to take place during January to April, outside the main migratory period.

Thirteen species of seasnakes may occur in and around the Project Area according to the EPBC Act PMST. None of these species is listed as threatened.

No EPBC Act-listed seabirds are listed as likely to occur in and around the Project Area according to the EPBC Act PMST.

6 MAJOR ENVIRONMENTAL HAZARDS AND CONTROLS

In accordance with Regulations 13(3) and 13(3A) of the OPGGS (Environment) Regulations, the environmental impacts and risks associated with the activity, and any unplanned consequences of the activity are evaluated and described in the EP.

The environmental risk management process applied to the Fletcher Finucane Development Project is based on the Santos management system, which in turn is based on AS/NZ ISO 31000. The AS/NZ ISO 31000 risk management process is consistent with that described in the OPGGS (Environment) Regulations and is based on the key steps shown in Figure 6.1.


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Figure 6.1 Risk assessment process

The EP describes this process, and its outcomes in detail, including the environmental hazards, and risk management controls. These are summarised in Table 6.1.

Table 6.1 Major Environmental Hazards and controls

Major Environmental

Hazards Risk Management controls

Disturbance to seabed features

and benthic fauna

No sensitive seabed features in Project Area as confirmed by geotechnical and geophysical survey (undertaken in August 2011).

No anchoring by the Rockwater 2 within Project Area – use of dynamic positioning. Mooring and anchoring will only be undertaken in an emergency (e.g., poor weather) outside the Project Area.

Subsea structures are gravity foundations (rather than piled).

Flowlines to be laid on seabed rather than trenched.

Materials handling and transfer procedures in place to minimise the risk of dropped objects.

Post-installation ROV survey will be conducted to identify dropped objects or other discrepancies.


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Major Environmental


Underwater Noise

Project Area is outside key migration, feeding and breeding areas for noise-sensitive cetaceans (e.g., humpback whales).

The high-frequency acoustic transducers are planned to be used for 2 hours at each of the eight locations, a total of only 16 hours.

Peak humpback whale migration near the Project Area occurs from July to September, and construction will take place from January to April, thus avoiding the peak humpback migration seasons.

Subsea infrastructures are gravity foundations, avoiding the use of piling.

Helicopter transfers are infrequent, and minimised as far as possible

DSV thrusters and engines are maintained in accordance with the Rockwater 2 planned maintenance system (TM Master).

Cetacean observations will be recorded on DSEWPC cetacean sighting proformas and returned to DSEWPC.

Atmospheric emissions

No waste incineration on board.

Use of marine-grade diesel, which is low in sulphur content, thus minimising the generation of SOx.

Engines and mobile equipment are maintained in accordance with the PMS (TM Master) to ensure their operation at maximum efficiency.

Vessel fuel consumption is recorded by the Chief Engineer, enabling the detection and remedy of combustion issues early.

Lighting

Project is distant from turtle-nesting beaches and seabird rookeries.

Minimal lighting will be pointed down towards the water – the key area requiring water lighting is at the over-boarding arch, where the flowline enters the water.

Vessel lighting will be managed in accordance with maritime safety standards.

Interference with cetaceans

Project Area is outside key migration, feeding and breeding areas for threatened cetaceans (e.g., humpback whale).

Peak humpback whale migration near the Project Area occurs from July to September, and construction will take place from January to April, meaning there is little chance of vessel interactions with humpbacks.

Vessel will be stationary or slow-moving while in the Project Area.

The Australian Guidelines for Whale and Dolphin Watching (2005) for sea-faring activities will be implemented.

Cetacean observations will be recorded on DSEWPC cetacean sighting proformas and returned to DSEWPC.


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Major Environmental


Interference with other users

No anchoring, thereby reducing the potential for entanglement or damage to fishing equipment.

Vessel lit in accordance with maritime safety requirements to alert other users to presence.

Marine navigation equipment (Radar, AIS) and communication equipment are provided on the project vessels in accordance with maritime requirements, to alert other users to presence of the vessels.

Consultation has taken place with affected maritime safety authorities, fishing industry bodies and individual fishing companies to notify them of the location and timing of the construction campaign.

Stakeholder consultation indicates there is very little to no commercial fishing in or around the Project Area, making interference with vessels or subsea fishing equipment unlikely.

The development location will be included in a Notice to Mariners.

24-hour visual, radio and vessel radar watch from the Rockwater 2 to monitor for presence of other vessels.

Discharge of sewage and grey water to ocean

A MARPOL-compliant sewage treatment plant (STP) is fitted to the Rockwater 2 that treats sewage and greywater.

There will be no discharge of untreated sewage.

The vessel has a current and valid Statement of Compliance for Sewage Pollution Prevention.

The STP is maintained in accordance with the PMS (TM Master).

Sewage discharged is monitored and recorded on the sewage discharge log and the Vessel Environmental Performance Report.

Discharge of putrescible (galley

waste) waste to ocean

The galley macerator will macerate food scraps to a diameter of at least 25 mm before being disposed of overboard, in compliance with MARPOL Annexes IV and V.

The vessel has a current and valid Statement of Compliance for Sewage Pollution Prevention.

The macerator is maintained in accordance with the PMS (TM Master).

If the macerator fails, no unmacerated food waste will be disposed overboard. All food waste will be bagged and sent ashore for disposal in accordance with the Shipboard Waste Management Manual.

Cooking oils and greases will be collected in containers and transported back to shore for disposal in accordance with the Shipboard Waste Management Manual.


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Major Environmental


Discharge of contaminated

deck/bilge water to ocean

Vessel equipment is arranged to minimise the likelihood of discharge overboard (i.e., permanent rotating machinery (engines, generators) and the ROV spread are located in bunded / enclosed areas so any spills are not lost overboard). These areas are drained to the oily water separator (OWS).

Chemical storage and handling areas are bunded to prevent overboard discharge.

Any temporary equipment with potential for spill of chemicals or fuels (e.g., leak testing spread) will be located within temporary bunding so that spills are contained for subsequent treatment or disposal of the fluids, without uncontrolled discharge to the sea.

Bilges drain via the OWS (water is treated to have no greater than 15 ppm oil in water).

Discharge is monitored to ensure that any deviation from specification (<15 ppm) is directed to a storage tank and not discharged overboard outside specification.

The vessel has a current and valid International Oil Pollution Prevention Certificate.

Chemicals are stored in chemical storage lockers in the vessel.

A high focus will be placed on housekeeping:

o Spills to deck will be cleaned up immediately using SOPEP kits.

o SOPEP kits will be stored in various locations around the vessel and will be maintained fully stocked.

o Scupper plugs will be readily available for use in the event of a deck spill to prevent contaminants draining directly overboard.

Discharge of engine cooling water / brine to

ocean

Engines are maintained in accordance with the PMS (TM MASTER) so that they are running efficiently and not over-heating.

The vessel will bunker freshwater at the commencement of the campaign, and will replenish the used water with the production from the fresh water plant.

The fresh water plant is maintained in accordance with the PMS (TM Master) so that it is running efficiently. Discharge volumes are about 216 m3/day.


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Major Environmental


Discharge of hazardous and non-hazardous

waste

Waste shall not be disposed of to sea.

As far as practicable, waste will be transferred from the Rockwater 2 in sheltered waters (Port of Dampier), thus minimising the likelihood of accidental loss of waste to sea at the Project Area during transfers.

Project logistics planning will ensure only essential items are brought on board the vessel in line with project design requirements. Frequent interim mobilisations will be undertaken.

A Shipboard Waste Management Manual is in place, which specifies:

o The responsibilities of the Vessel Master, Offshore Manager, Waste Coordinator and crew with regard to waste management.

o Waste will be segregated according to recyclability (e.g., wood, plastic, glass, paper and cardboard).

o Waste segregation units (bins, drums, sacks or skips) must be used, and must be fully secured, watertight, undamaged and rust-free, stored in a vertical position, and clearly labelled. Lids must be kept on at all times to prevent wind-blown debris from escaping, and liquid waste must be stored in drop trays.

o Waste must be disposed of either via a supply vessel, platform/rig or via port.

o Waste Transfer Notes must be maintained.

o Garbage Records must be maintained (Vessel Environment Performance Report).

A Procedure for Ship-to-Ship/Ship-to-Platform Transfer of Equipment and Personnel is in place.

A post-installation ROV survey of the seabed will check for (and retrieve where possible within the technical capacity of the ROV) dropped objects.

Only licensed shore-based waste contractors will be used.

Discharge of treated seawater to

ocean

All subsea infrastructure will be pressure (strength) tested in the factory, minimising the offshore testing required to only a system leak test.

The volume of chemicals included with the leak test water is minimal (0.04% of total volume) and hence diluted on discharge.

The chemicals added to the leak test water are ‘Gold’ rated under OSPAR (i.e., they have a low environmental toxicity).

The leak test will be closely monitored to identify any loss of pressure, which would indicate system losses to sea.

Loss of hydrocarbon from

subsea infrastructure

The existing Mutineer production system will be isolated, depressurised and flushed with treated seawater back to the FPSO through the PFW treatment system prior to the intervention.

The MPFM flow path will be flushed prior to break-in and hence no hydrocarbon is present for discharge.

The potential discharge volume at Mutineer manifold and wellhead tie ins would be very low, with only a small percentage of the discharge volume potentially being hydrocarbon, refer discussion above.

Isolation, depressurisation and flushing requirements will be in place as described in Project Commissioning Philosophy.


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Major Environmental


Discharge of control fluids

The volume of discharge of control fluid will be low, of the order of 60 litres for the entire activity and will be monitored and recorded.

The selected fluid has low environmental impact, of OCNS ranking D or better.

Introduction of invasive marine

species

The Rockwater 2 will comply with the Department of Agriculture, Fisheries and Forestry (DAFF) biofouling guidelines prior to entry to Australian waters.

The vessel will have a hull clean and anti-fouling paint applied in dry-dock in Singapore immediately prior to mobilising to the Project Area.

A hull inspection will be conducted by a third-party inspection contractor, with the report issued to Subsea 7 and Santos prior to mobilisation.

Subsea 7 has prior experience of management of biofouling risk with the Rockwater 2 and other vessels operating in Australian waters.

The Rockwater 2 will have to pass AQIS ballasting requirements (Australian Ballast Water Management Requirements) prior to entering Australian waters.

The Rockwater 2 has a Ballast Water Management Plan in place.

Diesel spill

The Project Area is located at least 5 nm (9.3 km) from the Dampier Shipping Fairway.

Refuelling is planned to take place in sheltered waters and not in the Project Area.

The Rockwater 2 is equipped with sophisticated navigation aids and competent marine crew to assist in avoiding vessel collisions.

Consultation with AMSA has taken place and notification will occur during mobilisation of the Rockwater 2 to the Project Area.

The vessel’s location will be included in the Notice to Mariners issued by the AHS immediately prior to the campaign’s commencement.

Adherence to NOPSEMA accepted Construction Vessel Safety Case.

The Rockwater 2 is a double-skinned vessel, with segregated fuel tanks, thus the likelihood of a collision leading to a diesel spill is minimised.

The segregated fuel tank arrangement of the Rockwater 2 minimises the volume of diesel lost in the event of a collision.

The Subsea 7 Bunker Handling procedure will be implemented during refuelling.

Bunkering will only take place during daylight hours.

Dry-break couplings are fitted to transfer hoses.

Automatic shutdown of pumping in the event of a spill to sea.

SOPEP material is available on board and personnel are trained in its use.

The Oil Spill Contingency Plan will be implemented in the event of a spill to sea.


FF-1200-PLN-0007 Page 23 of 25 Rev 0

7 MANAGEMENT APPROACH

The Fletcher Finucane Subsea Construction campaign will be managed in compliance with the Environment Plan accepted by NOPSEMA under the OPPGS (Environment) Regulations, and other relevant environmental legislation. The Environment Plan describes the Santos risk management processes that will be applied to manage the environmental risk of the activity.

The objective of the EP is to ensure that potential adverse impacts on the environment associated with the activity, during both routine and non-routine operations, are identified, and will be reduced to ALARP and will be of an acceptable level. This includes the definition of the risk controls that are in place to manage each of the identified risks and aspects.

The EP defines environmental performance objectives and performance standards that are in place to manage each of the identified environmental risks and aspects. These objectives and performance standards are consistent with those risk control measures described above. The EP also describes the specific measurement criteria which are used to demonstrate that these performance objectives are achieved.

An implementation strategy is described in the EP. The implementation strategy identifies the systems, practices and procedures which are in place to ensure that any environmental risks and impacts are continuously being reduced to ALARP and performance objectives and standards are met. The implementation strategy establishes the chain of command and identifies the roles & responsibilities and training/competency requirements for all personnel in relation to implementing, managing the activity in accordance with the EP, and review of the EP.

The EP describes the types of monitoring and auditing that will be undertaken, the reporting requirements for environmental incidents and reporting on overall compliance of the activity with the EP.

8 STAKEHOLDER CONSULTATION

Santos has been actively involved in stakeholder engagement in the Dampier region since the development of the Mutineer Exeter production facility in 2005. The Mutineer Exeter development initiated the long-term relationship between Santos and relevant stakeholders such as commercial and recreational fisheries, conservation organisations, recreational organisations, non-government organisations, and government agencies.

In October 2011 as part of the Fletcher Finucane Development drilling campaign, Santos commenced the Fletcher Finucane Development stakeholder consultation process.

The stakeholders were contacted again in July 2012 in relation to the construction campaign relative to the activity covered by this EP. The stakeholders were provided with the relevant information in accordance with the OPGGS (Environment) Regulations in the form of an “invitation to comment” document.

Comments received back from the consultation process did not identify any significant concerns or impacts on any stakeholders, and those comments that were received have


FF-1200-PLN-0007 Page 24 of 25 Rev 0

been incorporated into the activity requirements. The stakeholders which were consulted have included the following:

Department of Mines and Petroleum (DMP) – Petroleum Environment Branch

Australian Maritime Safety Authority (AMSA)

Australian Hydrographic Service (AHS)

Department of Defence

WA Department of Transport (DoT), Oil Spill Response Coordination

WA Department of Environment and Conservation (DEC)

Museum of WA (Maritime Heritage)

AFMA – Environmental Assessments Division

WA Department of Fisheries (DoF)

WA Fishing Industry Council (WAFIC)

Commonwealth Fisheries Association

RecFish West

Game Fishing Association (WA)

WA Northern Trawl Owners Association

Northern Fishing Companies Association

Westmore and Shark Bay Seafoods

A. Raptis & Sons

Northern Fishing Companies Association

Centre for Whale Research (Western Australia) Inc.

Australian Institute of Marine Science (AIMS)

Australian Marine Conservation Society

WA Marine Parks and Reserves Authority (MPRA)

Dampier Port Authority

Australian Marine Oil Spill Centre (AMOSC)


FF-1200-PLN-0007 Page 25 of 25 Rev 0

The consultation process is ongoing including providing updates to those stakeholders who expressed a desire to be updated about the construction phase (such as AMSA, AHS).

The stakeholder consultation process will also be ongoing as the Fletcher Finucane Development moves into its subsequent (operational) phase.

9 CONTACT DETAILS

The Santos contact for this EP is:

Michael Jacobsen

Santos Project Manager

Phone: (08) 9333 9509

Email: [email protected]

Additional information regarding Santos can be obtained from its website at: www.santos.com.

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Fletcher Finucane Subsea Construction Phase Environment Plan … · 2012-12-24 · Subsea 7 Subsea...

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