ENV IRONMENTA L ASSESSMENT & NAT URAL RESOURCE MANA GEM ENT
C O N S U L T A N T S
MALLACOOTA OCEAN ACCESS BOAT RAMP at BASTION POINT
Independent Compliance Audit of Environmental Management Plan
2015 Operation and Maintenance
Prepared For:
East Gippsland Shire March, 2017
Final Report
Mallacoota Ocean Access Boat Ramp at Bastion Point: Independent Compliance Audit of Operation and Maintenance Environmental Management Plan - 2015
East Gippsland Shire
ETHOS NRM
E N V I R O N M E N T A L A S S E S S M E N T & N A T U R A L R E S O U R C E M A N A G E M E N T
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Cover Photo: Bastion Point Boat Ramp, November, 2016
ETHOS NRM Pty Ltd
ABN: 44 104 999 528
PO Box 204, 162 Macleod St Bairnsdale, Vic. 3875 Telephone: 03-5153 0037 Facsimile: 03-5153 0038 E-mail: [email protected] Website: www.ethosnrm.com.au
Ethos NRM Pty Ltd Document Control
Client East Gippsland Shire
Title Mallacoota Ocean Access - Bastion Point Boat Ramp: Independent Audit of Environmental Management Plan 2015 Operation and Maintenance
Author Eric Sjerp
Manager Eric Sjerp
Reviewed Internally
Version V3.1
Electronic File Name 16043 egsc bastion point emp op and maint audit 2015 v3.1.docx
Date Last Saved 30th March 2017
Date Last Printed No. Vers. / Format Date
Distribution: Internal review 1 v1.0 Feb 2017
Chris Waites – East Gippsland Shire 1 V2.1 30 March 2017
Chris Waites – East Gippsland Shire 1 V3.1 30 March 2017
Mallacoota Ocean Access Boat Ramp at Bastion Point: Independent Compliance Audit of Operation and Maintenance Environmental Management Plan - 2015
East Gippsland Shire
ETHOS NRM
E N V I R O N M E N T A L A S S E S S M E N T & N A T U R A L R E S O U R C E M A N A G E M E N T
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ................................................................................................. 4
1 INTRODUCTION ........................................................................................................ 5
1.1 MALLACOOTA OCEAN ACCESS BOAT RAMP .............................................................. 5 1.2 OPERATION AND MAINTENANCE ENVIRONMENTAL MANAGEMENT PLAN ...................... 5 1.3 AUDITOR’S STATEMENT ........................................................................................... 6
2 INDEPENDENT AUDIT .............................................................................................. 7
2.1 AUDIT SCOPE AND OBJECTIVE ................................................................................. 7 2.2 AUDIT PERIOD ........................................................................................................ 8 2.3 OPERATIONS AND MAINTENANCE ACTIVITIES ............................................................ 8
2.3.1 Area of Operations and Maintenance ............................................................ 8 2.3.2 Definitions and Activities ................................................................................ 9
2.4 AUDIT METHODOLOGY AND STANDARDS .................................................................. 9 2.5 AUDIT MEETINGS, AUDIT EVIDENCE AND SITE INSPECTIONS .................................... 10 2.6 COMPLIANCE RANKINGS ........................................................................................ 11
3 DECLARED NON-CONFORMANCES ......................................................................12
4 AUDIT FINDINGS .....................................................................................................12
4.1 AUDIT CRITERIA .................................................................................................... 12 4.2 AUDIT FINDINGS ................................................................................................... 12 4.3 POSITIVE AUDIT OUTCOMES .................................................................................. 15 4.4 NON-COMPLIANCES AND AREAS FOR IMPROVEMENT ............................................... 15
5 CONCLUSION ..........................................................................................................17
6 REFERENCES ..........................................................................................................19
7 APPENDIX 1: DETAILED AUDIT FINDINGS............................................................20
TABLES
Table 1: Compliance Ranking Definitions
Table 2: Summary of Audit Criteria Compliance Findings
Table 3: Recommended Improvements for Operational Phase
Table 4: Summary of previous Audit Findings
PLOTS
Plot1: MOABR EMP Compliance Results
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ETHOS NRM
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ABBREVIATIONS
CEMP Construction Environmental Management Plan
CMA Coastal Management Act
DELWP Department of Environment Land Water and Planning (formerly DEPI)
DEPI Department of Primary Industries (now DELWP)
DoE Department of Environment (Commonwealth)
EGSC East Gippsland Shire Council
EMP Environmental Management Plan
EPBC Environment Protection and Biodiversity Conservation Act 1999
GPM GPM Construction Pty Ltd
GP Gippsland Ports
MOA Mallacoota Ocean Access
MOABR Mallacoota Ocean Access Boat Ramp
O&M EMP Operations and Maintenance Environmental Management Plan
PDS Project Delivery Standards (also referred to as Audit Criteria)
Mallacoota Ocean Access Boat Ramp at Bastion Point: Independent Compliance Audit of Operation and Maintenance Environmental Management Plan - 2015
East Gippsland Shire
ETHOS NRM
E N V I R O N M E N T A L A S S E S S M E N T & N A T U R A L R E S O U R C E M A N A G E M E N T
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EXECUTIVE SUMMARY
Mallacoota Ocean Access Boat Ramp was constructed in 2014 by East Gippsland Shire to facilitate improved launching facilities and ocean access at Bastion Point for commercial and recreational vessels. The facility became operational in December 2014.
Operation and maintenance of Mallacoota Ocean Access Boat Ramp (MOABR) is subject to a variety of statutory approvals and conditions, which are reflected in an approved Operation and Maintenance Environmental Management Plan (O&M EMP).
This Independent Audit seeks to establish the extent to which Operation and maintenance of MOABR by East Gippsland Shire complies with the requirements of the O&M EMP. The Independent Audit is not an assessment of the boat ramp design or environmental values at Bastion Point. The Audit relates only to an assessment of compliance with the approved MOABR O&M EMP.
All Audit Criteria (or Project Delivery Standards) within the O&M EMP have been assessed by the Auditor against agreed Compliance Rankings (Table 1). A summary of the Audit Findings is presented Table 2 and below. Detailed audit findings are listed in Appendix 1.
Based on the evidence made available by East Gippsland Shire and on-site inspections, the Auditor has found approximately half of the assessed criteria to be Fully Compliant. However, the Auditor has also found areas of Minor Non-Conformance, a considerable lack of recorded documentation, and significant scope for improvement during future operational & maintenance activities at MOABR.
In summary:
46.7% of Audit Criteria are Fully Compliant (14 out of 30)
20.0% of Audit Criteria are Compliant but Improvements Required (6 out of 30)
10.0% of Audit Criteria are a Minor Non-Compliance (3 out of 30)
0% of Audit Criteria are a Major Non-Compliance (0 out of 30)
0% of Audit Criteria are a Critical Non-Compliance (0 out of 30)
23.3% of Audit Criteria are Undetermined due to lack of Evidence (7 out of 30)
An additional seven Audit Criteria are considered Not Applicable for this audit assessment.
46.7%
20.0%
10.0%
0.0% 0.0%
23.3%
Fully CompliantCompliant
Minor Non-ComplianceMajor Non-Compliance
Mallacoota Ocean Access Boat Ramp at Bastion Point: Independent Compliance Audit of Operation and Maintenance Environmental Management Plan - 2015
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1 INTRODUCTION
Ethos NRM Pty Ltd, Environmental Assessment and Natural Resource Management Consultants were engaged by East Gippsland Shire Council to undertake an independent compliance audit of the Operation and Maintenance Environmental Management Plan applicable to operation and maintenance of the Mallacoota Ocean Access Boat Ramp located at Bastion Point.
This Audit Report covers the 2015 calendar year period. A separate report covers the 2016 period.
1.1 Mallacoota Ocean Access Boat Ramp
Mallacoota Ocean Access Boat Ramp (MOABR) was constructed by East Gippsland Shire to facilitate improved launching facilities and ocean access at Bastion Point for commercial and recreational craft up to approximately 10 metres in length.
An existing boat ramp at Bastion Point was historically used by recreational fishers, commercial Abalone divers, fisheries patrols, emergency response agencies, Victorian Water Police, Coast Guard, and for servicing Gabo Island. The original boat ramp was used intensively during summer and Easter holiday periods, resulting in car and boat trailer parking often reaching capacity.
Bastion Point is also a popular surfing location and recreational swimming / beach bathing spot for both local residents and tourists.
Construction of the Mallacoota Ocean Access Boat Ramp at Bastion Point was undertaken under contract by GPM Constructions on behalf of East Gippsland Shire. Construction was completed in December 2014.
Ongoing operation and maintenance of the boat ramp facility is the responsibility of East Gippsland Shire, and is undertaken in accordance with various regulatory approvals and an Operation and Maintenance Environmental Management Plan (O&M EMP).
1.2 Operation and Maintenance Environmental Management Plan
Operation and maintenance of the Mallacoota Ocean Access Boat Ramp at Bastion Point is subject to a variety of statutory approvals which originate from a 2009 Ministerial Assessment of the Mallacoota Ocean Access Boat Ramp Environmental Effects Statement and subsequent Coastal Management Act Consent (DELWP, 2013). Conditions contained within these approvals are reflected in the Operation and Maintenance Environmental Management Plan.
The O&M EMP outlines the environmental management requirements to be complied with during operation and maintenance of the Ocean Access Boat Ramp and its related infrastructure at Bastion Point, Mallacoota.
Version ‘Final V2’ dated 1st December 2014 (Crossco, 2014) is the most recent O&M EMP document and forms the basis of this Audit. It is based on an earlier approved Plan (Version 5, dated 6th November, 2014) that addressed both construction and operation & maintenance requirements. The current ‘Final V2’ O&M EMP document only addresses operation & maintenance requirements
Environmental and statutory approvals addressed by the O&M EMP include the Environment Protection and Biodiversity Conservation Act 1999 (Commonwealth), Environment Effects Act 1978, Coastal Management Act 1995, Environment Protection Act 1970, and the Planning and Environment Act 1987.
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The O&M EMP comprises several parts/sections based on general requirements, operational and maintenance aspects, and an environmental risk assessment and register. In summary the approved EMP includes:
• Performance requirements for environmental management during the operational phase (post-construction) of the boat ramp;
• Performance requirements for environmental management of maintenance activities undertaken during the operational phase of the boat ramp;
• Risk assessment framework and project risk register; • Environmental objectives and targets for different components of the operation and
maintenance works; • Environmental controls, including standards and limits, to ensure that specific
objectives and targets are achieved; and • Responsibilities for implementing the EMP.
The Environmental Risk Assessment and Register included in Appendix 5 of the O&M EMP provides an evidence-based assessment of the potential impacts from construction and operational activities upon specific environmental values. The risk treatment / mitigation measures identified in the Environmental Risk Assessment are reflected as environmental controls in the O&M EMP.
Key risk events identified in the Risk Assessment and Register are:
• Airborne noise; • Coastal ecology and habitat; • Terrestrial habitat; and • Removal of native vegetation.
Specific environmental performance standards and targets to address the risk are referred to as Project Delivery Standards (PDS) and Environmental Controls in the O&M EMP.
East Gippsland Shire, as the ‘owner and operator’ of Mallacoota Ocean Access Boat Ramp, is responsible for ensuring that all operational and maintenance activities relating to the MOABR comply with the O&M EMP. Council staff are responsible for day-to-day activities, and engage consultants / contractors for specialist tasks.
1.3 Auditor’s Statement
This Independent Audit has been completed in accordance with a Project / Audit Brief and is generally consistent with the requirements of ISO19011:2003. The Auditor is suitably qualified, experienced and competent to undertake the audit.
Ethos NRM has previously completed a variety work for East Gippsland Shire Council (EGSC), including:
Independent Compliance Audit of Environmental Management Plan for
construction of Mallacoota Ocean Access Boat Ramp
Development of management plans for foreshore, recreation / open space and
ecologically sensitive areas managed by EGSC;
Development and involvement in preparation of environmental and planning
strategies for rural land and ecologically sensitive areas;
Independent reviews and status assessments of previously prepared management
plans;
Independent compliance reviews of previously completed revegetation works; and
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Independent assessment and reporting of environmental values and potential
impacts of proposed Council works.
In addition, Ethos NRM regularly prepares environmental impact reports to accompany planning permit applications by third parties, which are then subsequently assessed by Council statutory planning staff for approval.
Ethos NRM has had no direct involvement in undertaking environmental assessments, reporting or gaining approvals associated with establishment or operation of the MOABR. Ethos NRM did provide Council with advice regarding the scope and content of the Project/Audit Brief for this Independent Audit.
East Gippsland Shire Council prior to engaging Ethos NRM, and Ethos NRM prior to accepting this audit contract, each assessed the potential for a conflict of interest, and concluded that the previous work by Ethos NRM in no way compromises the independence of Ethos NRM in undertaking this audit, nor does the previous work constitute a Conflict of Interest.
2 INDEPENDENT AUDIT
2.1 Audit Scope and Objective
This Independent Audit seeks to establish the extent to which operation and maintenance of the Mallacoota Ocean Access Boat Ramp complies with the requirements of the O&M EMP.
The Objectives of the Independent Audit, as specified in the Audit Brief (East Gippsland Shire Council, September 2016), is to:
1. Undertake an independent compliance audit of the approved EMP including:
independently assess implementation of the EMP; and
independently gather information that verifies compliance against all the
Environmental Controls specified in the EMP.
2. Advise East Gippsland Shire of any non-conformances with the EMP.
3. Provide a written audit report to East Gippsland Shire outlining:
the extent of compliance against all Environmental Controls specified in the
EMP; and
any potential improvements to the audit process for subsequent ‘operational
and maintenance’ audits.
Importantly, the Audit Brief highlights that the Independent Audit is not an assessment of the boat ramp design or environmental values at Bastion Point. The Audit relates only to an assessment of compliance with the approved MOABR O&M EMP.
This Independent Audit relates only to the operational and maintenance phase of MOABR. The Audit Brief explicitly excludes auditing of construction aspects, which have been separately audited following completion of the construction phase (Ethos NRM, 2015).
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2.2 Audit Period
This Audit Report covers operations and maintenance activities at Mallacoota Ocean Access Boat Ramp for the 2015 calendar year period, including the latter part of December 2014 following completion of the ramp’s construction.
Conditions of the Coastal Management Act Consent require that a separate independent operations and maintenance audit is undertaken and reported upon annually.
A separate Audit Report covers the 2016 period.
Both the 2015 and 2016 audits were undertaken simultaneously between November 2016 and March 2017, with audit meetings, provision of audit evidence, and assessment of audit evidence occurring concurrently.
2.3 Operations and Maintenance Activities
2.3.1 Area of Operations and Maintenance
The area within which Council’s operations and maintenance activities are permitted to occur is defined by a formal Crown Land Lease area on Plan of Crown Allotment OP123390, which is illustrated in Appendix 1 of the O&M EMP, and is reproduced below.
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2.3.2 Definitions and Activities
Operations is defined in the Audit Brief as:
Operations include the launching and / or retrieval of vessels and temporary berthing of vessels associated with launching and retrieval of vessels. Operational activities will be carried out by commercial, recreational and Government Agency users.
Operations will be undertaken in accordance with the Maritime Safety Operational Manual as required by condition 3 of the Coastal Management Act consent dated 14 January 2013.
Maintenance is defined in the Audit Brief as:
Maintenance works are defined as works required or undertaken to preserve the infrastructure constructed in good working order, and as near to “as designed” and “as constructed” for as long as possible.
These works may be routine or on an “as required” basis.
Maintenance works are the responsibility of EGSC and will be carried out by or on behalf of EGSC.
Operations and maintenance activities that may occur at MOABR are listed in Appendix 1 of the O&M EMP, and include but are not necessarily limited to:
Establish environmental & cultural heritage management controls and OHS in
accordance with approved plans
Removal of sand and/or kelp from boat ramp
Landscaping
Timber structures (jetty, bollards, walkway)
Roadways and pedestrian access paths
Breakwater
Navigational aids
Ablutions
Lighting
Pavement line marking
Signage
Navigational channel
Servicing infrastructure (electricity, sewer, water)
Parking of vehicles and associated trailers.
2.4 Audit Methodology and Standards
Requirements of AS/NZS ISO 19011:2014 Guidelines for Auditing Management Systems have been used to direct this audit. AS/NZS ISO 19011:2003 provides a clear systematic approach for undertaking audits and allows for a consistent approach across multiple or recurrent audits. Definitions used throughout this Audit Report are generally consistent with AS/NZS ISO 19011:2003.
The audit methodology is consistent with the Audit Brief issued by Council and with the Coastal Management Act Consent conditions stipulated by the Department of Environment Land Water and Planning (DELWP, 2013).
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The environmental requirements, standards and limits assessed by this audit are listed as Project Delivery Standards (PDS) and Environmental Controls in the O&M EMP, and are referred to in this report as Audit Criteria for the purposes of assessing compliance with the O&M EMP. The individual Audit Criteria are listed in the ‘Register of Environmental Objectives and Targets’ of the O&M EMP (Table 4 to Table 10, Appendix 4), and in Table 3 of the O&M EMP.
An Audit Plan was developed in cooperation with East Gippsland Shire Council staff to direct specific audit tasks and to ensure the audit objectives and methodology were clear.
The audit methodology involved:
Audit Commencement Meeting and development of an agreed Audit Plan
Confirmation of an agreed suite of Audit Criteria
Confirmation of compliance rankings
Exchange of audit evidence
Audit meetings
On-site inspection at Bastion Point and East Gippsland Shire’s Mallacoota depot
office
Audit assessment
Issuing of Draft Audit Findings
Issuing of Final Audit Findings and Audit Closure
2.5 Audit Meetings, Audit Evidence and Site Inspections
Ethos NRM undertook both the 2015 and 2016 audits simultaneously between November 2016 and March 2017, with site inspections, audit meetings and provision of audit evidence occurring concurrently. However separate Audit Reports have been prepared for each Audit Period. This report covers the 2015 period, including the latter part of December 2014.
An audit inception / commencement meeting was held on 3rd November, 2016, where the Audit Plan, method and Audit Criteria were confirmed.
Subsequent meetings, phone calls and email exchanges took place over the following months in order to facilitate the transfer and assessment of information and Audit Evidence provided by Council staff.
All available evidence was freely provided to the Auditor.
A portion of the Audit Evidence provided by EGSC applies to both the 2015 and 2016 audits, and given that both audits were undertaken simultaneously, there is considerable repetition in a number of the Audit Findings within the two Audit Reports.
A site inspection and meeting was undertaken by Ethos NRM on 18th November, 2016, which afforded the Auditor with first-hand observational evidence of the operating boat ramp. An earlier site inspection was also conducted by Ethos NRM on 30th April, 2015 as part of the MOABR Construction EMP Compliance Audit (Ethos NRM, 2015)
Assessment of Audit Evidence occurred between November 2016 and February 2017. The Auditor also benefited from his familiarity of the general Bastion Point boat ramp environs, having visited the site on numerous occasions before and subsequent to this audit, for matters other than this audit.
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A Final Audit report was issued to East Gippsland Shire on 30th March, 2017, and Audit Closure is expected to occur in early April, 2017.
2.6 Compliance Rankings
Compliance Rankings and definitions listed in the Audit Brief were confirmed at the Commencement Meeting as being appropriate for use in undertaking a compliance audit of the O&M EMP.
Table 1 lists the adopted compliance rankings.
The ranking applied to an O&M EMP non-conformance (ie Minor, Major or Critical), was determined by assessing the extent to which the non-conformance impacts on environmental values, as outlined in the environmental risk register included in Appendix 5 of the O&M EMP, and with the regulatory (legal) approvals governing that specific non-conformance.
Table 1: Compliance Ranking Definitions
Compliance Rank / Grade
Description
Fully Compliant There is sufficient evidence to confirm that actions have been undertaken, prepared and/or implemented in full compliance with the requirements of the auditable element.
Compliant but with Improvements Required
There is evidence to confirm that actions have been implemented to achieve compliance with the auditable element, but improvements are required to achieve Full Compliance.
Minor Non-Compliance
The evidence shows that actions are not in full compliance with the requirements of the auditable element but it is unlikely that this will cause the environment to be seriously affected.
Major Non-Compliance
The evidence shows that actions are not in full compliance with the requirements of the auditable element and this gives risk to a high potential that the environment will be seriously affected if the non-compliance is not rectified.
Critical Non-Compliance
The evidence shows that actions are not in full compliance with the requirements of the auditable element and this gives rise to a serious or imminent risk to the environment.
Undetermined There is insufficient evidence to make a judgement on compliance.
Not Applicable The auditable element falls outside the scope of the audit, eg. work relevant to the environmental control/standard has not yet commenced.
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3 DECLARED NON-CONFORMANCES
During the commencement and audit meetings, East Gippsland Shire staff indicated they believed there had been no non-compliant incidents or events relating to the 2015 operational and maintenance period at MOABR.
4 AUDIT FINDINGS
4.1 Audit Criteria
The environmental requirements, standards and limits evaluated by this audit are listed as Project Delivery Standards and Environmental Controls in the MOABR O&M EMP, and are referred to in this audit report as Audit Criteria for the purposes of assessing compliance with the O&M EMP.
Detailed Project Delivery Standards and Environmental Controls are listed in Table 4 to Table 10 of the ‘Register of Environmental Objectives and Targets’, Appendix 4 of the O&M EMP. The tables address the following Audit Criteria themes:
General Management of Maintenance Activities
Marine-based works
Dredging / excavation and plume
Channel maintenance schedule
Dredged / excavated material management
Land based standards
Additional Audit Criteria listed in Table 3 of the O&M EMP relate to External Notification and Reporting.
A summary of the Audit Criteria assessed for this Audit are listed in Table 2 of this report, with further detail provided in Appendix 1 (Detailed Audit Findings).
4.2 Audit Findings
A detailed assessment of compliance against all Audit Criteria is documented in Appendix 1: Detailed Audit Findings.
Audit findings are summarised in Table 2 below. Findings are listed only for the operational and maintenance phase of the MOABR. An audit of construction activities was completed separately in 2015 (Ethos NRM, 2015).
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A total of thirty (x30) Audit Criteria have been assessed by the Auditor, with the following results (excluding seven (x7) additional Not Applicable results) which are also depicted in Plot 1:
46.7% of Audit Criteria are Fully Compliant (14 out of 30)
20.0% of Audit Criteria are Compliant but Improvements Required (6 out of 30)
10.0% of Audit Criteria are a Minor Non-Compliance (3 out of 30)
0% of Audit Criteria are a Major Non-Compliance (0 out of 30)
0% of Audit Criteria are a Critical Non-Compliance (0 out of 30)
23.3% of Audit Criteria are Undetermined due to lack of Evidence (7 out of 30)
Excludes Audit Criteria that are Not Applicable (7 criteria)
Approximately half (46.7%) of the assessed Audit Criteria are Fully Compliant. There were no Critical or Major Non-Compliances, however 10.0% of Audit Criteria are a Minor Non-Compliance.
A significant number Audit Criteria were Undetermined (23.3%) due to a lack of Audit Evidence, Compliant but Improvements Required (20.0%).
46.7%
20.0%
10.0%
0.0% 0.0%
23.3%
Fully CompliantCompliantMinor Non-ComplianceMajor Non-ComplianceCritical Non-ComplianceUndetermined
Plot 1: MOABR O&M EMP Compliance Results for 2015
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Table 2: Summary of Audit Criteria Compliance Findings
Audit Criteria
Fu
lly
Co
mp
lia
nt
Co
mp
lia
nt
bu
t
imp
rovem
en
ts
req
uire
d
Min
or
No
n-
Co
mp
lia
nc
e
Ma
jor
No
n-
Co
mp
lia
nc
e
Cri
tic
al
No
n-
Co
mp
lia
nc
e
Un
de
term
ine
d
(du
e t
o la
ck
of
Ev
ide
nce
)
No
t
Ap
pli
ca
ble
1. Hours of operation x1
2. Airborne noise x1
3. Waste management x3 x2
4. Equipment maintenance x1
5. Fuels, oils, chemicals and hazardous goods
x1
6. Emergency response preparedness
x1 x1 x1
7. Marine pests x4
8. Vessel Refuelling x1
9. Cetacean – vessel manoeuvring x1
10. Heritage (marine based) – identification of potential relics
x1
11. Dredging / excavators and plume
x1 x1
12. Dredging / excavator schedule x1
13. Consideration of season sensitivities
x1
14. Dredged / excavated material disposal
x1 x1
15. Disposal site monitoring x1
16. Excavation, placement and stockpiling of material
x1
17. 17. Removal and management of native vegetation
x2
Continued …..
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Table 2: continued
Audit Criteria
Fu
lly
Co
mp
lia
nt
Co
mp
lia
nt
bu
t
imp
rovem
en
ts
req
uire
d
Min
or
No
n-
Co
mp
lia
nc
e
Ma
jor
No
n-
Co
mp
lia
nc
e
Cri
tic
al
No
n-
Co
mp
lia
nc
e
Un
de
term
ine
d
No
t
Ap
pli
ca
ble
18. Weeds and pest animals X3
19. Sediment transport control x2
20. External notification and reporting
x1 x1 x1
TOTALS 14 6 3 0 0 7 7
% TOTALS (excl Not Applicable)
46.7% 20.0% 10.0% 0.0% 0.0% 23.3%
4.3 Positive Audit Outcomes
Positive outcomes from this independent compliance audit of the MOABR EMP applicable to operations and maintenance activities at Bastion Point during 2015 are:
Successful operation of boat ramp infrastructure at Bastion Point following
completion of construction period
No major operational incidents resulting in catastrophic environmental impact
Approximately half (46.7%) of assessed Audit Criteria are Fully Compliant
No Critical Non-Compliances
No Major Non-Compliances
Details are documented in Appendix 1: Detailed Audit Findings.
4.4 Non-compliances and Areas for Improvement
Key adverse findings from this independent compliance audit of the MOABR EMP applicable to operations and maintenance activities at Bastion Point during 2015 are:
10% Minor Non-Compliant Audit Criteria
Large proportion (23.3%) of Audit Criteria were Undetermined due to a lack of
Audit Evidence
Large proportion (20.0%) of Audit Criteria were Compliant but Require
Improvements
Failure to record completed SOP and SWMS documentation
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Lack of evidence relating to storage and handling of fuels, oils, chemicals and
hazardous goods, particularly for contractor’s equipment
Emergency response procedures were not adequately developed or tested,
including for contractor activities
Failure to notify government agencies of potential environmental incident relating
to vessels striking navigation hazard (shallow rocks)
A number of recommendations for improvements have been identified throughout the Detailed Audit Findings listed in Appendix 1. These recommendations are summarised in Table 3 and reflect both the “Compliant but with Improvements Required” compliance grading, and less critical improvements associated with outcomes that still have scope for improvement during the ongoing operational and maintenance phase of MOABR.
All Non-Compliances and areas for Improvement are documented in Appendix 1: Detailed Audit Findings.
Table 3: Recommended Improvements
Recommendations for Improvements
Amend O&M EMP to better distinguish between maintenance activities and
machinery operational hours.
Amend O&M EMP to better reflect when operational and maintenance activities
are most suitable to occur (eg influence of tides etc).
Amend Weekly Inspection Logs to document actual maintenance activities and
machinery operational hours.
Require all subcontractors to record machinery hours, and retain copies of
contractor’s records.
Document waste management sub-contractor arrangements.
Document sub-contractor response arrangements for oil spill and noxious
substance discharge.
Modify EGSC Weekly and Monthly Inspection Logs to include inspection for all
on-site hazardous materials.
Create Hazardous Substances Register and establish system for documenting
and retaining records of all hazardous materials used sub-contractors.
Create Daily Inspection Log for use during onsite use of any mechanical
equipment requiring refuelling.
Develop and test emergency response procedure (including for all contractors),
and retain records in accordance with App 8 & 10 of O&M EMP.
Document staff oil spill response training.
Document existence of contractor’s oil spill response kits.
Update EMP to reflect most current version of EPA Publication 949.3.
Update EMP to reflect most current version of Australian Ballast Water
Management Requirements.
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Recommendations for Improvements
Numerous 2015 operations and maintenance activities undertaken in 2015 are
not adequately covered in the O&M EMP. Amend O&M EMP to include
additional Channel Maintenance criteria, such as:
Kelp removal
Ramp cleaning
Breakwater stability
Navigation hazards
Issuing of Notice to Mariners
Amend Weekly Inspection Logs to include checks for domestic animal
restrictions.
Amend Weekly Inspection Logs to include checks for imported soil.
Amend O&M EMP to clarify intent of DEPI Notification Audit Criteria.
5 CONCLUSION
Operation and maintenance of the Mallacoota Ocean Access Boat Ramp at Bastion Point during 2015 was subject to a variety of ‘Environmental Controls’ specified in the Mallacoota Ocean Access Boat Ramp Operations and Maintenance Environmental Management Plan (MOABR O&M EMP).
This Independent Audit has assessed thirty (x30) individual Audit Criteria (ie Standards) to determine compliance of operations and maintenance activities with the requirements of the O&M EMP.
Operation and maintenance activities during 2015 did not involve dredging, instead the key activities involved ramp cleaning, kelp removal, placement of navigation warning markers, signage and removal of navigation hazards comprising shallow in-situ rocks and dislodged breakwater material.
Based on the evidence made available by East Gippsland Shire and on-site inspections, the Auditor has found approximately half of the assessed criteria to be Fully Compliant. However, the Auditor has also found areas of Minor Non-Conformance, a considerable lack of documentation, and significant scope for improvement during future operational & maintenance activities at MOABR.
In summary:
46.7% of Audit Criteria are Fully Compliant (14 out of 30)
20.0% of Audit Criteria are Compliant but Improvements Required (6 out of 30)
10.0% of Audit Criteria are a Minor Non-Compliance (3 out of 30)
0% of Audit Criteria are a Major Non-Compliance (0 out of 30)
0% of Audit Criteria are a Critical Non-Compliance (0 out of 30)
23.3% of Audit Criteria are Undetermined due to lack of Evidence (7 out of 30)
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An additional seven Audit Criteria are considered Not Applicable for this audit assessment.
Based on these Audit Findings, there has been general compliance with the EMP’s requirements, except for the following issues:
Failure to record completed SOP and SWMS documentation
Lack of evidence relating to storage and handling of fuels, oils, chemicals and
hazardous goods, particularly for contractor’s equipment
Emergency response procedures were not adequately developed or tested,
including for contractor activities
Failure to notify government agencies of potential environmental incident relating
to vessels striking navigation hazard (shallow rocks)
Importantly, there is no evidence to suggest any wilful acts resulting in environmental degradation. East Gippsland Shire’s Works Supervisor responsible for operation and maintenance of the MOABR at Bastion Point has, following completion of the construction period, actively and diligently managed the site with the resources available to him.
The Auditor believes non-compliances and the necessary improvements resulting from the 2015 operations and maintenance period have occurred partly as a result of unfamiliarity with the boat ramp in its first year of operation, and partly due to insufficient emphasis being placed by Council on fully incorporating the O&M EMP’s requirements into the daily operational and maintenance aspects of MOABR. In particular, support for Council’s Works Supervisor to establish a more comprehensive and rigorous record keeping system will enable Council to demonstrate greater compliance with the O&M EMP.
In addition (and as stated previously by Ethos NRM at the completion of the Construction EMP Audit), the Auditor believes that the EMP should be reviewed and edited to better reflect the actual operations and maintenance works undertaken at Bastion Point. Re-grouping the EMP content to combine similar Standards and Controls (Audit Criteria) will provide Council with a better tool to more efficiently record and demonstrate compliance across all the necessary issues. Updating the MOABR O&M EMP will also greatly improve Council’s ability to manage the facility more efficiently.
The Auditor acknowledges the manner in which all relevant information and evidence was made readily and freely available during the course of this Audit.
ERIC SJERP Date: 30th March, 2017 Principal Consultant / Managing Director
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6 REFERENCES
DELWP, 2013. Coastal Management Act approval, Department of Environment Land Water and Planning, January 2013
East Gippsland Shire, 2016. Audit Brief, September 2016
Ethos NRM, 2015. Mallacoota Ocean Access Boat Ramp at Bastion Point: Independent Compliance Audit of (Construction) Environmental Management Plan. Prepared for East Gippsland Shire Council
Crossco, 2013. Mallacoota Ocean Access Boat Ramp Environmental Management Plan. Prepared for East Gippsland Shire Council
Crossco, 2014. Operations and Maintenance Environmental Management Plan: Bastion Point, Mallacoota. Prepared for East Gippsland Shire Council
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7 APPENDIX 1: Detailed Audit Findings
Project Delivery Standard /
Audit Criteria Evidence Audit Findings and Comments Compliance
Table 4: GENERAL MANAGEMENT OF MAINTENANCE ACTIVITIES
Objective:
To plan and implement maintenance aspects of MOA.
To ensure materials are appropriately stored, handled and disposed of.
Application:
Throughout all MOA maintenance activities
Target:
Conformance with all environmental limits and controls Operations and Maintenance Risk Register.
1. Hours of operation Evidence Audit Findings and Comments Compliance
a. All activities must be
conducted in accordance
with EPA guidelines, except
where explicitly restricted
within this EMP, or by
legislation.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Notes from interview with EGSC Works Supervisor
Copies of EGSC emails regarding operations and maintenance activities
Maintenance hours are specified in O&M EMP
Mon – Fri, 7am – 5pm
Sat, 7am – 3pm
Sun, 9am – 3pm for emergency works O&M EMP makes poor distinction between “maintenance hours” and “ machinery hours”.
No detailed records available of machinery hours.
Available evidence suggests majority of operations and maintenance activities generally occurred during daytime.
Extended hours of operation occurred due to machinery breakdowns, and as an emergency response to prevent adverse environmental impacts from oil and/or fuel discharge.
No evidence that extended hours caused serious environmental impact.
Compliant but Requires Improvement
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Project Delivery Standard /
Audit Criteria Evidence Audit Findings and Comments Compliance
Auditor concludes the available evidence suggests that operations and maintenance activities occurred as specified except where in ‘emergency situations’ and to prevent adverse environmental impacts. The Audit Criteria is considered Compliant but Requires Improvement.
Improvement:
Amend O&M EMP to better distinguish between maintenance activities and machinery operational hours.
Amend O&M EMP to better reflect when operational and maintenance activities are most suitable to occur (eg influence of tides etc).
Amend Weekly Inspection Logs to document actual maintenance activities and machinery operational hours.
Require all subcontractors to record machinery hours, and retain copies of contractor’s records.
2. Airborne noise Evidence Audit Findings and Comments Compliance
a. All activities must be
conducted in accordance
with Noise from Industry in
Rural Victoria (NIRV: EPA
Publication 1411).
None sighted
No Evidence of quantitative noise monitoring against Standards.
Auditor concludes there is a lack of evidence for quantitative noise monitoring, hence the Audit Criteria cannot be assessed with confidence.
Undetermined (due to lack of Evidence)
3. Waste management Evidence Audit Findings and Comments Compliance
a. All EGSC works crew
contractors engaged to have
independent waste
management arrangements
to include waste
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Photographs
EGSC Weekly and Monthly Inspection Logs record maintenance activities relating to waste, bins and toilets.
Bins observed by Auditor
No evidence of sub-contractor waste management arrangements.
Compliant but Requires Improvement
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Project Delivery Standard /
Audit Criteria Evidence Audit Findings and Comments Compliance
minimization, containment,
segregation and appropriate
reuse, recycling, treatment
and disposal.
Auditor’s visual observations
No indication or suggestion that a breach occurred.
Auditor concludes the available evidence suggests Full Compliance with the Audit Criteria.
Improvement:
Document waste management sub-contractor arrangements.
b. All waste must be removed
from the site.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Photographs
Auditor’s visual observations
EGSC Weekly and Monthly Inspection Logs record waste and bins maintenance activities.
Photographs demonstrate site to be free of ‘waste’ from operations and maintenance activities.
No waste observed on site by Auditor.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Fully Compliant
c. The handling and disposal of
unexpected materials
identified during dredging/
excavation/maintenance (eg.
inert debris such as concrete
and timber) to be included in
waste management
arrangements.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Notes from interview with EGSC Works Supervisor
Copies of EGSC emails regarding operations and maintenance activities
No record of unexpected materials being encountered during operations and maintenance activities.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Fully Compliant
d. All waste bins must be
wildlife proof so as to
eliminate litter and access by
wildlife and/or encourage
vermin
Auditor’s visual observations
Photographs
EGSC Weekly Inspection Logs
EGSC Monthly Inspection
Evidence suggests on-site waste bins are fitted with lids.
No report of wind-blown litter. No report of injury to wildlife.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Fully Compliant
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Project Delivery Standard /
Audit Criteria Evidence Audit Findings and Comments Compliance
Logs
e. All waste to be managed in
accordance with:
Environment Protection Act 1970 (Vic)
Pollution of Waters by Oil and Noxious Substances Act 1986 (Vic)
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Auditor’s visual observations
Photographs
EGSC Weekly and Monthly Inspection Logs record waste and bins maintenance activities.
Auditor observed oil spill response equipment at EGSC depot.
EGSC Works Supervisor advised Auditor that oil spill response equipment was stationed onsite for all works activities, and contractors carried additional oil spill response equipment.
No evidence sighted by Auditor of sub-contractor procedures for oil spill and noxious substance discharge.
Auditor found no record of oil spill or discharge of noxious substance having occurred.
Auditor concludes the available evidence suggests no oil spill or discharge of noxious substance occurred, however insufficient records exist relating to sub-contractor response arrangements for oil spill and noxious substance discharge. The Audit Criteria is considered Compliant but Requires Improvement.
Improvement:
Document sub-contractor response arrangements for oil spill and noxious substance discharge.
Compliant but Requires Improvement
4. Equipment maintenance Evidence Audit Findings and Comments Compliance
a. Maintenance programs will
be implemented for all plant
and equipment as defined in
EGSC procedures and the
Occupational Health and
Safety Regulations 2007
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
EGSC Weekly and Monthly Inspection Logs mention equipment and machinery use, however no record of machinery maintenance logs or pre-start checks etc.
No equipment records available from contractors for waste management, diving inspections, ramp cleaning etc
Auditor concludes there is a lack of evidence relating to equipment maintenance, particularly for contractor’s equipment, hence the Audit Criteria cannot be
Undetermined (due to lack of Evidence)
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Project Delivery Standard /
Audit Criteria Evidence Audit Findings and Comments Compliance
(Vic). assessed with confidence.
Improvement:
Establish system for documenting and retaining records of all sub-contractor equipment maintenance, including daily pre-start checks and tool-box inspections
5. Fuels, oils, chemicals
and hazardous goods Evidence Audit Findings and Comments Compliance
a. Storage and handling of
chemicals in accordance
with:
Dangerous Goods Act 1985 (Vic)
Pollution of Waters by Oil and Noxious Substances Act 1986 (Vic)
No documented evidence sighted
Auditor’s visual observations
No oil, fuel, noxious substances or dangerous goods are stored onsite at MOABR during normal operations (ie. when no equipment is used onsite).
No records available of any oils, fuels, noxious substances or dangerous goods that were stored onsite by sub-contractors at MOABR.
Auditor did however observe oil spill response equipment at EGSC depot.
No completed Standard Operating Procedures (SOP) / Safe Work Method Statements (SWMS) for ‘Working Near or Over Water’ (Appx 7 O&M EMP) were sighted.
Auditor concludes there is a lack of evidence relating to storage and handling of fuels, oils, chemicals and hazardous goods, particularly for contractor’s equipment. Auditor also concludes that failure to record completed SOP and SWMS documentation is not compliant with the intent of the Audit Criteria, but that there was no resulting impact to the environment, and hence is considered a Minor Non-Compliance.
Improvement:
Modify EGSC Weekly and Monthly Inspection Logs to include inspection for all on-site hazardous materials.
Create Hazardous Substances Register and establish system for documenting and retaining records of all hazardous materials used sub-contractor’s .
Create Daily Inspection Log for use during onsite use of any mechanical
Minor Non-Compliance
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Project Delivery Standard /
Audit Criteria Evidence Audit Findings and Comments Compliance
equipment requiring refuelling.
6. Emergency response
preparedness Evidence Audit Findings and Comments Compliance
a. Development and testing of
emergency response
procedures, integrated with
the EMP, including provision
for fuel, oil and chemical
spills.
Notes from interview with EGSC Works Supervisor
Auditor’s visual observations
Photographs
EGSC Works Supervisor advised Auditor that EGSC staff completed Oil Spill Response Training. However no records or documented evidence of staff training was sighted by the Auditor.
Auditor observed oil spill response equipment at EGSC depot.
No evidence of Register of Emergency Response Tests (App 8 of O&M EMP) being completed.
No evidence of Emergency Test and Incident Review Form (App 10 of O&M EMP) being completed.
No evidence of contractor Emergency Response Test.
Auditor concludes emergency response procedures were not adequately developed or tested, including for contractor activities, but that no record exists of an emergency incident seriously affecting the environment, and hence represents a Minor Non-Compliance.
Improvement:
Develop and test emergency response procedure (including for all contractors), and retain records in accordance with App 8 & 10 of O&M EMP.
Minor Non-Compliance
b. All dredging vessels /
excavation to have oil spill
response kits. Relevant
personnel to be trained in its
use.
Notes from interview with EGSC Works Supervisor
Auditor’s visual observations
Photographs
Auditor observed oil spill response equipment at EGSC depot.
EGSC Works Supervisor advised Auditor that EGSC staff completed Oil Spill Response Training.
EGSC Works Supervisor advised Auditor that oil spill response equipment was stationed onsite for all works activities, and contractors carried additional oil spill response equipment.
Compliant but Requires Improvement
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Project Delivery Standard /
Audit Criteria Evidence Audit Findings and Comments Compliance
No evidence of staff training or spill kit being stationed onsite during maintenance activities were sighted by the Auditor.
No evidence of Contractor equipment having oil spill response equipment.
Auditor concludes oil spill response kits were available onsite and staff training occurred, however no documented evidence exists. The Audit Criteria is considered Compliant but Requires Improvement.
Improvement:
Document staff oil spill response training.
Document existence of contractor’s oil spill response kits.
c. Gippsland Region Marine
Pollution Contingency Plan is
amended to reflect projected
increased activity following
construction
Gippsland Region Marine Pollution Contingency Plan
Online copy of Marine Pollution Contingency Plan highlights risk of increased marine pollution event occurring at Bastion Point boat ramp.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Fully Compliant
Table 5: MARINE-BASED WORKS
Objective:
To appropriately manage marine-based works.
To minimise disturbance to and appropriately manage non-Aboriginal heritage.
To minimise impacts on cetaceans.
To mitigate the impact of oil spills or other marine pollution events.
Application:
All marine-based MOA activities.
Target:
Conformance with all environmental limits and controls.
7. Marine pests – Evidence Audit Findings and Comments Compliance
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Project Delivery Standard /
Audit Criteria Evidence Audit Findings and Comments Compliance
If Dredging / Excavation
equipment is mobilized
a. Marine pest inspection and
certification of contract
dredge and support vessel is
required before mobilization,
where these are sourced
from outside Mallacoota Inlet.
Certification must be
received from the final port of
call, before mobilization.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Kina Diving quotation to EGSC (Oct, 2015)
Internal EGSC emails (November, 2015)
No dredge / support vessel equipment was used during 2015 operations and maintenance activities.
Boat used by diving contractor (Kina Diving from Geelong, Vic) to remove navigation hazard (rock) in December 2015. Marine pest inspection and certification not required.
Audit Criteria is Not Applicable.
Not Applicable
b. All vessels to comply with
Protocol for Environmental
Management – Domestic
Ballast Water Management in
Victorian State Waters, EPA
Publication 949.2 (April 2008)
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Not applicable as vessels requiring ballast water were not used during 2015 operations and maintenance activities.
Note: EPA Publication 949.3 (July 2010) is most current version.
Improvement:
Update EMP to reflect most current version of EPA Publication 949.3.
Not Applicable
c. All vessels to comply with
Australian Ballast Water
Management Requirements,
AQIS (June 2007).
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Not applicable as vessels requiring ballast water were not used during 2015 operations and maintenance activities.
Note: Australian Ballast Water Management Requirements, DAFF (November 2011) is most current version.
Improvement:
Update EMP to reflect most current version of Australian Ballast Water Management Requirements.
Not Applicable
d. Train staff undertaking
construction and
None sighted
Not applicable as dredge, support vessel(s) and/or marine equipment likely to contain marine pests was not brought to site from outside Mallacoota Inlet.
Not Applicable
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Project Delivery Standard /
Audit Criteria Evidence Audit Findings and Comments Compliance
maintenance activities in
identification of marine pests,
and reporting procedure.
8. Vessel Refuelling Evidence Audit Findings and Comments Compliance
a. All refuelling to take place in
accordance with Marine
Safety Victoria’s guideline,
Port Management
Regulations, Gippsland
Ports’ Harbour Master
directions.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
No on-water refuelling of vessels was necessary during 2015 operations and maintenance activities.
Refuelling of small craft (diving contractor) was undertaken on land.
Refuelling of maintenance (earthmoving) equipment was undertaken on land.
Oil and fuel spill kits kept were stationed onsite during maintenance activities, although no records of such were sighted by the Auditor (refer to 5 above).
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Fully Compliant
9. Cetaceans – vessel
manoeuvring Evidence Audit Findings and Comments Compliance
a. If within 300m of a dolphin or
whale the vessel must not:
Approach a whale or
dolphin head on; or
Be in the path of a
whale or dolphin; or
Separate any whale or
dolphin from a group; or
Come between a
mother and a calf; or
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
EGSC Works Supervisor advised Auditor that no Cetaceans (whale or dolphin) were sighted during maintenance activities involving vessels (Diving contractor)
Weekly and Monthly Inspection Logs make no mention of Cetaceans (whale or dolphin) being sighted during vessel use.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Improvement:
Include recording of Cetaceans sightings on Weekly and Monthly Inspection Logs.
Compliant but Requires Improvement
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Project Delivery Standard /
Audit Criteria Evidence Audit Findings and Comments Compliance
Drop or lower an
anchor overboard from
the vessel.
b. Within 300m of a whale or
dolphin, the vessel must:
Maintain a constant
speed that does not
exceed 5 knots; and
Avoid sudden changes
in direction; and
Maneuver the vessel to
a distance of at least
200m from the whale or
dolphin if it shows any
sign of disturbance,
when safe to do so.
10. Heritage (marine based) –
identification of potential
relics
Evidence Audit Findings and Comments Compliance
a. If potential relics are
identified during construction
activities, the process
described in Annexure 11
Response Process will be
followed.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
EGSC Works Supervisor advised Auditor that no heritage relic material was encountered during 2015 operations and maintenance activities.
Weekly and Monthly Inspection Logs make no mention of heritage relic material being encountered.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Fully Compliant
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Table 6: DREDGING / EXCAVATION and PLUME
Objective:
To appropriately manage dredging / excavation activities and sediments.
To minimize the area of channel and seabed disturbed and appropriately manage the material removed.
To protect assets, beneficial uses and values from long-term adverse effects to dredging-related water quality effects.
Application:
All relating to maintenance of navigation depth activities.
The disposal of dredged / excavated material.
Use of dredges / excavators and associated equipment.
Target:
Conformance with all environmental limits and controls.
11. Dredging / Excavation
and plume Evidence Audit Findings and Comments Compliance
a. Dredging and/or excavation
must remain within the
identified channel zones, and
will be confirmed by recorded
GPS data.
Channel zones” are shown
on Crossco Drawing No.
1579/007-B included in
Appendix 12
EGSC Weekly Inspection Logs, including annotated Crossco Drawing No. 1579/007-B
EGSC Monthly Inspection Logs, including annotated Crossco Drawing No. 1579/007-B
Coastal Management Act Consent application and approval for removal of rock outside permitted zone
Photographs
No dredging or excavation occurred during 2015 operations and maintenance activities.
Navigation hazard (rocks) located outside permitted zone was removed by diving contractor (Kina Diving from Geelong, Vic) in December 2015, in accordance with separate Coastal Management Act consent approval. Application made in August 2015.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Fully Compliant
b. Recording of equipment
activity on log sheets will
include the following
information as a minimum:
EGSC Weekly Inspection Logs, including annotated Crossco Drawing No. 1579/007-B
EGSC Monthly Inspection
No dredging or excavation occurred during 2015 operations and maintenance activities, other than the navigation hazard (rocks) removed separately by Diving contractors.
Hence no recording of dredged sand management was required and the Audit
Not Applicable
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Dredge/Excavator:
Management of sand from
….., and
Sailing and placement of
sand to …..
Other Equipment
Management of sand from
….
Reason for use of equipment
Logs, including annotated Crossco Drawing No. 1579/007-B
Criteria is hence Not Applicable.
Table 7: CHANNEL MAINTENANCE SCHEDULE
Objective:
To develop an appropriate maintenance schedule, taking into account the seasonal sensitivities of the Mallacoota Inlet assets,
beneficial uses and values.
Application:
All channel Maintenance activities.
Target:
Conformance with all environmental limits and controls.
12. Dredging / excavator
schedule Evidence Audit Findings and Comments Compliance
a. Dredging / excavation to take
place in accordance with
construction plans showing
channel location and depths
EGSC Weekly Inspection Logs, including annotated Crossco Drawing No. 1579/007-B
EGSC Monthly Inspection Logs, including annotated Crossco Drawing No. 1579/007-B
Ramp cleaning invoice from sub-contractor
Photographs
Notice to Mariners issued
No dredging or excavation occurred during 2015 operations and maintenance activities.
Navigation hazard (rocks) located outside permitted zone was removed by diving contractor (Kina Diving from Geelong, Vic) in December 2015, in accordance with separate Coastal Management Act consent approval.
Monthly Inspection Log includes prompt for channel depth measurement. Drawing No. 1579/007-B includes table for recording channel depths.
Operational aspects of MOABR recorded on Weekly and Monthly Inspection Logs.
Rock movement and dislodgement from breakwater recorded on Monthly
Compliant but Requires Improvement
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by Gippsland Ports Inspection Logs.
Sand shoaling recorded on Weekly and Monthly Inspection Logs.
Kelp build-up within channel and on ramp is recorded on Weekly and Monthly Inspection Logs.
Slippery condition of concrete ramp apron and cleaning requirement recorded on Weekly and Monthly Inspection Logs and by photographs.
Navigation Hazards, including displaced breakwater rocks, recorded on Weekly and Monthly Inspection Logs and by photographs.
Navigation Warning signs erected by EGSC, 10th February, 2015
Notice to Mariners issued by Gippsland Ports for navigation hazards, installation of danger warning buoys, and missing danger warning buoys.
Auditor concludes the available evidence adequately demonstrates Compliance with the Audit Criteria but improvements are required.
Improvements:
Numerous 2015 operations and maintenance activities undertaken in 2015 are not adequately covered in the O&M EMP.
Amend O&M EMP to include additional Channel Maintenance criteria, such as:
Kelp removal
Ramp cleaning
Breakwater stability
Navigation hazards
Issuing of Notice to Mariners
13. Consideration of
seasonal sensitivities Evidence Audit Findings and Comments Compliance
a. Dredging /excavation
activities planned with a
particular awareness and
EGSC Weekly Inspection Logs
EGSC Monthly Inspection
No dredging or excavation occurred during 2015 operations and maintenance activities.
Maintenance associated with ramp cleaning and kelp removal occurred throughout
Fully Compliant
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regard for high recreational
use periods (Easter, Summer
holidays, long weekends)
Logs
Ramp cleaning invoice from sub-contractor
Photographs
year.
Removal of navigation by diving contractor occurred during summer holiday period, prior to Christmas peak tourist period
EGSC Works Supervisor advised Auditor all works were timed to avoid peak tourist periods wherever possible, but was subject to availability of contractors
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Table 8: DREDGED / EXCAVATED MATERIAL MANAGEMENT
Objective:
To manage and track the placement of removed material.
To relocate removed material and manage appropriately within approved near-shore locations.
Application:
All dredged / excavated and removed material placement.
Target:
Conformance with all environmental limits and controls.
14. Dredged / excavated
material placement Evidence Audit Findings and Comments Compliance
a. All dredged / excavated sand
placement to be placed:
within 300m of the “channel
zone” shown on Crossco
Drawing No. 1579/007-B
(included in Appendix 12);
and
to the west of the
breakwater; and
above the low water mark
in the intertidal zone.
No dredging or excavation occurred during 2015 operations and maintenance activities, and no dredged material was placed on beach.
Audit criteria is Not Applicable.
Not Applicable
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b. Kelp removed from the ramp
and/or channel will be
disposed of in accordance
with EPA requirements.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Photographs
Kelp build-up within channel and on ramp is recorded on Weekly and Monthly Inspection Logs.
Auditor sighted no records of Kelp being physically removed.
Auditor sighted no records of where Kelp (if any) was disposed to.
Auditor concludes there is a lack of available evidence relating to removal and disposal of Kelp, hence the Audit Criteria cannot be assessed with confidence.
Undetermined (due to lack of Evidence)
15. Disposal site monitoring Evidence Audit Findings and Comments Compliance
a. Site inspections will be
recorded and photographs
taken to provide evidence of
appropriate management.
The results of inspections will
be included in performance
reporting.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Photographs
No dredging or excavation occurred during 2015 operations and maintenance activities, and hence no dredged material was placed on beach.
Audit criteria is Not Applicable.
Not Applicable
Table 9: LAND BASED
Objective:
To manage operations and maintenance activities.
Application:
All land based works.
Target:
Conformance with all environmental limits and controls.
Conformance with approved Cultural Heritage Management Plan (CHMP).
16. Excavation, placement
and stockpiling of
material
Evidence Audit Findings and Comments Compliance
a. All Maintenance works to be EGSC Weekly Inspection Cultural Heritage Management Plan details requirements for avoidance and Fully
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completed in accordance
with the approved:
Cultural Heritage
Management Plan
(CHMP);
Construction drawings
and specifications.
Logs
EGSC Monthly Inspection Logs
Photographs
Cultural Heritage Management Plan
management of aboriginal cultural sites during construction period. Less emphasis is placed on operational and maintenance phase.
No dredging or excavation occurred during 2015 operations and maintenance activities.
Known sites of Cultural Significance were not disturbed during 2015 operations and maintenance activities.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Compliant
17. Removal and
management of native
vegetation
Evidence Audit Findings and Comments Compliance
a. All temporary site facilities
and vehicle management to
be within defined areas
approved by EGSC
Notes from interview with EGSC Works Supervisor
Available evidence indicates that 2015 operations and maintenance activities were undertaken by contractors as instructed by EGSC Works Supervisor. All activities were undertaken within the approved MOABR area as defined in the O&M EMP. No additional designated area was defined by EGSC.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Fully Compliant
b. All operations and
maintenance to be completed
in accordance with each as
may be amended from time-
to-time: Coastal Management
Act consent dated
14/01/2013, Crown Lease
conditions, and DEPI Native
Vegetation removal approval
dated 4 September 2011
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Notes from interview with EGSC Works Supervisor
Copies of EGSC emails regarding operations and maintenance activities
Photographs
Available evidence indicates that 2015 operations and maintenance activities were undertaken within the approved MOABR area as defined in the O&M EMP, the Coastal Management Act Consent.
Available evidence indicates 2015 operations and maintenance activities resulted in no additional vegetation removal.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Fully Compliant
18. Weeds and pest animals Evidence Audit Findings and Comments Compliance
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a. Domestic animals must be on
a lead at all times in
accordance with East
Gippsland Shire local law
requirements.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Notes from interview with EGSC Works Supervisor
Weekly Inspection Logs do not include checks for presence of domestic animals (dogs) on leads.
No other records sighted containing information regarding presence of domestic animals during 2015 operations and maintenance activities.
Auditor concludes there is a lack of evidence indicating checks restricting domestic animals, hence the Audit Criteria cannot be assessed with confidence.
Improvement:
Amend Weekly Inspection Logs to include checks for domestic animal restrictions.
Undetermined (due to lack of Evidence)
a. No topsoil will be imported to
the site
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Notes from interview with EGSC Works Supervisor
Weekly Inspection Logs do not include checks for importation of topsoil.
No other records sighted regarding topsoil importation restrictions during 2015 operations and maintenance activities.
Auditor concludes there is a lack of evidence indicating checks restricting importation of topsoil were undertaken, hence the Audit Criteria cannot be assessed with confidence.
Improvement:
Amend Weekly Inspection Logs to include checks for imported soil.
Undetermined (due to lack of Evidence)
b. All material imported to the
site will be free of seed stock,
unless specifically approved
EGSC
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Notes from interview with EGSC Works Supervisor
No other records sighted regarding topsoil importation restrictions during 2015 operations and maintenance activities.
There is no evidence that EGSC issued approval for importation of seed stock.
Auditor concludes there is a lack of evidence indicating checks restricting importation of seed stock were undertaken, hence the Audit Criteria cannot be assessed with confidence.
Undetermined (due to lack of Evidence)
19. Sediment transport
control Evidence Audit Findings and Comments Compliance
a. No contaminated stormwater
to leave the construction site.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Weekly Inspection Logs do not include checks for stormwater management.
No operations and maintenance activities undertaken in 2015 were likely to generate contamination other than oil or fuel spills form car park area or ramp
Fully Compliant
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Notes from interview with EGSC Works Supervisor
apron. Oil and fuel spills are addressed in Criteria 5 and 8 above.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
b. Where vegetation cover is
inadequate to protect soil, silt
traps must be constructed
and maintained and form part
of regular inspections
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Notes from interview with EGSC Works Supervisor
Photographs
Weekly Inspection Logs do not include checks for vegetation cover or soil erosion.
Photographs and Auditor’s observations suggest areas disturbed during construction of MOABR were rehabilitating adequately and no soil or silt traps were required.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Fully Compliant
Table 3: EXTERNAL NOTIFICATION and REPORTING REQUIREMENTS – OPERATIONS and MAINTENANCE PHASE
Objective:
To report performance against EMP to Government agencies and stakeholder groups
Application:
None listed
Target:
None identified
20. Reporting Requirement Evidence Audit Findings and Comments Compliance
Pollution event or imminent environmental hazard (as defined in Environmental Auditor Guidelines for Conducting Environmental Audits, Publication 953.2, October 2007, EPA, Victoria)
Copy of relevant report
EPA, DEPI, GP, TSV
Notification within 4 hours.
Incident report required.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
No pollution event or environmental incident occurred requiring reporting.
Weekly and monthly Inspection Logs record installation of navigation warning marker (and replacement markers).
Minor Non-Compliance
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Notification to GP as soon as
practicable.
Notes from interview with EGSC Works Supervisor
Notice to Mariners
GP letter to EGSC regarding unsafe navigation conditions and vessels striking displaced breakwater rocks
Notice to Mariners issued by Gippsland Ports following request by EGSC.
No record of incidents involving vessels hitting navigation hazards (shallow in-situ rocks and displaced breakwater rocks).
Weekly and monthly Inspection Logs do not include checks for notifiable incidents.
No evidence of notification to Government agencies that vessels had struck navigation hazards (shallow in-situ rocks and displaced breakwater rocks).
Auditor believes vessels striking shallow rocks could potentially have led to vessel damage or grounding and high risk of fuel pollution event, and that Government agencies should have been notified.
Hence the Auditor concludes a Non-Compliance has occurred in terms of failure to notify government agencies of potential environmental incident, but that there are no direct environmental implications.
Project Delivery Standard Evidence Audit Findings and Comments Compliance
DEPI
Notification within one
business day of verifying
non-conformance with a
PDS.
EGSC Weekly Inspection Logs
EGSC Monthly Inspection Logs
Notes from interview with EGSC Works Supervisor
No verified non-conformance occurred.
Auditor concludes the available evidence adequately demonstrates Full Compliance with the Audit Criteria.
Fully Compliant
Operational and Maintenance Activities
Evidence Audit Findings and Comments Compliance
DEPI
Notification within 14 days of
commencement and
completion.
Notes from interview with EGSC Works Supervisor
Request for Coastal Management Act consent to remove navigation hazard (two shallow rock areas north of ramp) using contract divers.
Email correspondence from EGSC
Auditor is uncertain if Audit Criteria requirement relates to notification of all Operational and Maintenance Activities at MOABR, or only those not authorised by existing approvals (eg CMA Consent).
EGSC notified DELWP (previously DEPI) that Construction phase of MOABR was complete and that Operational and Maintenance phase would commence.
EGSC sought and gained additional approval for removal of navigation hazard outside permitted work zone.
However there is no evidence or records that EGSC notified DELWP of commencement / completion of any specific operational and maintenance
Undetermined
(due to poorly defined Audit Criteria)
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activities, such ramp cleaning or removal of navigation hazard (rocks).
Auditor is unable to determine compliance with Audit Criteria.
Improvement:
Amend O&M EMP to clarify intent of DEPI Notification Audit Criteria.
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