EP104 & R1

Environment Plan

Geochemical Survey

EP104 & R1

Prepared for:

Gulliver Productions Pty Ltd

19 July 2019

360 Environmental Pty Ltd

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© Copyright 2019 360 Environmental Pty Ltd ACN 109 499 04

Document

Reference Revision

Prepared

by

Reviewed

by

Admin

Review

Submitted to Client

Copies Date

3238AB Rev 0 A INTERNAL DRAFT SS HT/MR NL 31/5/19

3238AB Rev 1 B CLIENT DRAFT 360 Rey N/A 1 Electronic (email) 4/6/19

3238AB Rev 2 C CLIENT FINAL (submission

to DMIRS)

360 DMIRS N/A 2 Hardcopies

1 Electronic (CD)

11/6/19

3238AB Rev 3 D CLIENT FINAL (submission

to DMIRS)

360 FJ - 1 Electronic 11/7/19

3238AB Rev 4 D CLIENT FINAL (3rd

submission to DMIRS

360 Rey - EARS Online 19/07/19

3238AB Environment Plan EP104 and R1 Canning Basin


360 Environmental Pty Ltd i

Table of Contents

Introduction .................................................................................................. 1

1.1 Overview ................................................................................................................ 1

1.2 Scope ..................................................................................................................... 1

1.3 Licence Holder and Operator Details ..................................................................... 1

Description of the Activity (Regulation 14(1)) ............................................... 3

2.1 Location.................................................................................................................. 5

2.2 Construction and Operational Details .................................................................... 8

2.3 Timeframes and Schedules .................................................................................... 8

Description of the Environment (Regulation 14(2)) ....................................... 9

3.1 Natural Environment .............................................................................................. 9

3.2 Flora, Vegetation and Fauna .................................................................................. 9

3.3 Soils and Land Systems ....................................................................................... 10

3.4 Hydrogeology ....................................................................................................... 11

3.5 Climate ................................................................................................................. 11

3.6 Heritage ............................................................................................................... 12

3.7 Socio-economic Environment ............................................................................... 13

3.8 Values and Sensitivities ....................................................................................... 13

Environmental Risk Assessment and Management (Regulation 14(3)) ........ 15

4.1 Risk Assessment Methodology ............................................................................ 15

4.2 Identification of Sources of Risk and Associated Impacts .................................... 15

4.3 Justification of ALARP and Acceptability ............................................................. 15

Objectives, Standards and Measurement Criteria (Regulation 14(5)) ......... 20

Legislation and Other Requirements (Regulation 14(6)) ............................. 23

6.1 Legislation ............................................................................................................ 23

6.2 International Conventions and Agreements ......................................................... 26

6.3 Australian Standards ............................................................................................ 26

6.4 Codes of Practice ................................................................................................. 26

6.5 Other Requirements ............................................................................................. 27

6.6 Referrals to other Government Agencies ............................................................. 27

Implementation Strategy (Regulation 15) ................................................... 28

7.1 Systems, Practices and Procedures ..................................................................... 28

7.2 Corporate Environmental Policy ........................................................................... 29

7.3 Roles and Responsibilities of Personnel ............................................................... 29

7.4 Training and Competencies .................................................................................. 31

7.5 Monitoring, Auditing, Management of Non-Conformance, and Review ............... 32

7.6 Record Keeping .................................................................................................... 33

7.7 Details of Chemicals and Other Substances........................................................ 34

Oil Spill Contingency Plan (Regulation 15(10)) ........................................... 35

8.1 Credible Spill Scenario ......................................................................................... 35

8.2 Spill Response Procedure .................................................................................... 35



360 Environmental Pty Ltd ii

Reporting (Regulations 16, 28, 29 and 30) .................................................. 38

9.1 Prestart and Cessation Notifications ................................................................... 38

9.2 Activity Reporting (Annual Environmental Reports) ............................................. 38

9.3 Incident Reporting ................................................................................................ 38

9.4 Emissions and Discharges Reports ...................................................................... 41

Stakeholder Engagement (Regulation 17) .................................................. 42

10.1 Principles of Stakeholder Engagement ................................................................ 42

10.2 Targeted Community and Stakeholder Engagement Strategy ............................. 42

10.3 Potential Stakeholders ......................................................................................... 42

10.4 Initial Project/Activity Engagement (During EP Development) ........................... 43

10.5 Ongoing Engagement (Post Approval) ................................................................. 44

10.6 Recording Stakeholder Engagement .................................................................... 44

References ................................................................................................. 45

List of Tables

Table 1: Titleholder Details ............................................................................................... 2

Table 2: Gulliver Productions Pty Ltd Contact Details ...................................................... 2

Table 3: Existing Well Co-ordinates and Status ................................................................ 6

Table 4: Timeframes .......................................................................................................... 8

Table 5: Aboriginal Heritage Sites – Lodged and Registered .......................................... 13

Table 6: Qualitative Risk Rating Matrix ........................................................................... 17

Table 7: Likelihood Classification .................................................................................... 17

Table 8: Consequence Classification .............................................................................. 17

Table 9: Risk Assessment ............................................................................................... 18

Table 10: Environmental Performance Objectives, Standards and Measurement Criteria

............................................................................................................................ 21

Table 11: Gulliver Integrated Management System ........................................................ 28

Table 12: Roles and Responsibilities ............................................................................... 30

Table 13: Summary of Reporting Requirements .............................................................. 39

Table 14: Potential Stakeholders .................................................................................... 42

Table 15: Stakeholder Engagement Table ....................................................................... 43



360 Environmental Pty Ltd iii

List of Plates

Plate 1: Soil Collecting Procedure (Source: Graystone Exploration Labs, Inc) ................. 4

Plate 2: Access route to EP 104 and R1 Survey Locations ............................................... 5

Plate 3: Climate Data from the Bureau of Meteorology (2019) ...................................... 12

Plate 4: Chain of Command ............................................................................................ 29

List of Figures

Figure 1: Site Location ...................................................................................................... 7

Figure 2: Vegetation Systems ......................................................................................... 47

Figure 3: Soil and Land Systems ..................................................................................... 48

Figure 4: Hydrology ......................................................................................................... 49

Figure 5: Conservation Features ..................................................................................... 50

Figure 6: Heritage ........................................................................................................... 51

List of Appendices

Appendix A Environmental Policy

Appendix B Master Document Register

Appendix C Spill Response Procedure



360 Environmental Pty Ltd 1

Introduction

1.1 Overview

Gulliver Productions Pty Ltd (Gulliver) is a wholly owned subsidiary of Rey Resources

Limited (Rey). Rey is an ASX-listed company (ASX.REY) focused on exploring and

developing energy resources in Western Australia’s Canning and Perth Basins. Rey

recently acquired the Gulliver assets in the Canning Basin including Stokes Bay-1 and

Point Torment-1 well sites (Retention Lease R1), West Kora-1 well site (Production

Licence L15) and EP 104.

1.2 Scope

This Environment Plan (EP) has been prepared for the proposed Geochemical Survey at

Stokes Bay-1 and Point Torment-1 well sites on Retention Lease R1, and Exploration

Permit EP104 (the ‘project’). This EP has been developed in accordance with the (then)

Department of Mines and Petroleum (DMP) ‘Guideline for the Development of Petroleum

and Geothermal Environment Plans in Western Australia’ (DMP 2016) under the

Petroleum and Geothermal Energy Resources (Environment) Regulations 2012

(PER(E)R).

Further, this EP provides Gulliver with a practical environmental performance tool for these

proposed activities.

This EP was established to identify key risks and potential environmental impacts during

the proposed activities at Stokes Bay-1, Point Torment-1 and EP104 to provide detailed

management and mitigation strategies to minimise environmental impacts during the

activities.

1.3 Licence Holder and Operator Details

Gulliver is the registered operator of EP104 and R1 under the Petroleum and Geothermal

Energy Resources (Environment) Regulations 2012. The following tables outline the

Titleholder and Operator Contact details.




Table 1: Titleholder Details

Title Registered

Holder Classification

/ Status Expiry Operator Address

EP104

(Exploration

Permit)

Gulliver

Productions

Pty Ltd

Live /

Active 29/7/2022

Gulliver

Productions

Pty Ltd

Suite 2, 3B

Macquarie

Street,

Sydney

2000

R1

(Retention

Lease)

Gulliver

Productions

Pty Ltd

Live /

Active 10/10/2022

Gulliver

Productions

Pty Ltd

Suite 2, 3B

Macquarie

Street,

Sydney

2000

Table 2: Gulliver Productions Pty Ltd Contact Details

Company Name Gulliver Productions Pty Ltd

Nominated Liaison Person Stanley Fu

Position Operations Manager

Business Address Suite 2, 3B Macquarie Street, Sydney 2000

Telephone Number +61 401019364

Email Address [email protected]




Description of the Activity (Regulation

14(1))

Gulliver proposes to conduct an oil and gas Geochemical Survey for EP 104 and R1 to

detect the gas bearing property of three traps. West Head and Saddleback traps were

found onshore on EP 104. In which, West Head is a Devonian Nullara carbonate reef trap;

and Saddleback is a Late Devonian-Early Carboniferous low-stand fan trap. The third trap,

an Anderson sandstone trap, was developed in the north-eastern area of R1. Accordingly,

this EP is required to address the proposed activities.

The proposed activities involved in the Geochemical Survey are as follows:

• A total of 76 soil samples at 100 m intervals along a pre-existing road at EP 104

• A total of 70 soil samples at 100 m intervals along a pre-existing road in the direction

of the extension to the offshore area in R1

• Sampling and detection will be conducted in accordance with normative methods for

soil geochemical surveys for gas and will analyse the distribution of anomalies.

The Geochemical Survey methods used, are as follows (Plate 1):

• One light vehicle and one personnel, will drive to sample points along existing track

• Stopping at designated points (marked by GPS)

• Using a small trowel to take soil samples of no more than 20 cm deep (200-300

grams) and placing sample in a sealed bag.

• Soil samples to be taken are small and will not result in holes that could interfere with

livestock or other land users, see Plate 1.

• Returning to vehicle, marking the sample bag and taking a GPS recording.

• Drive to next point and repeat until completed.

The activity is low impact with no requirement to clear vegetation and therefore minimal

impacts to vegetation or fauna. No infrastructure is required to be installed or used, no

chemicals or hazardous substances will be used, and no heavy machinery will be operated.

The Geochemical Survey will be undertaken by Thunderstone Energy Pty Ltd as a

subcontractor to Gulliver.




Soils are collected from the top two

inches and no deeper than 20 cm in

depth.

The sample will be approximately 200 to

300 grams unless the soil is unusually

coarse then a larger sample may be

needed to provide sufficient fine fraction.

Unlikely to be more than 500 g.

Three to five equal scoops will be

collected from the immediate area and

placed in the numbered bag.

Plate 1: Soil Collecting Procedure (Source: Graystone Exploration Labs, Inc)

Hydrocarbon spills from the light vehicle fuel tank pose a low risk and potential impact to

the environment and require a minor-moderate level of spill response. It is expected that

the fuel tank will have a maximum capacity of 180 litres of diesel. The light vehicle will

travel from Derby to the Geochemical Survey locations each day and undertake refuelling

at a petrol station in Derby.




2.1 Location

Two survey lines, in close proximity to each other, are proposed at both EP 104 and R1.

The two survey lines at R1 are 20 km north-east of Derby and the two lines at EP 104 are

50 km north-west of Derby, within the Lennard North Province in Western Australia’s

Canning Basin (Figure 1). The survey areas fall within the Shire of Derby/ West Kimberley,

which has a total population of approximately 7,705 people (Australian Bureau of

Statistics, 2016).

Gulliver has existing projects (wells) within R1, these are Stokes Bay-1 and Point Torment-

1. There are existing tracks into these project areas via raised causeways. These existing

tracks will be used for the Geochemical Survey.

Due to ground conditions, physical access is restricted to the dry season (May to October)

only. Access to EP 104 and R1 will be from Derby, along the Great Northern Highway,

heading north onto existing pastoral tracks (Plate 2).

Plate 2: Access route to EP 104 and R1 Survey Locations




Table 3: Existing Well Co-ordinates and Status

Well Site Easting Northing Latitude Longitude Status Date

Stokes

Bay-1 575414 8104830 -17.1399 123.7090 Suspended 05/12/2009

Point

Torment-1 578567 2102079 -17.1647 123.7388 Suspended 28/03/1995

CREATED APPROVED REVISIONCHECKED

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- NOTE THAT POSITION ERRORS CAN BE >5M IN SOME AREAS- LOCALITY MAP SOURCED LANDGATE 2017- OTHER DATA SOURCED LANDGATE 2018- AERIAL PHOTOGRAPHY SOURCED ESRI 2018 (© Western Australian Land Information Authority 2018)

0

HORIZONTAL DATUM AND PROJECTION

Gulliver ProductionsDerby, Canning BasinEnvironment Plan

COPYRIGHT: THIS DOCUMENT IS AND SHALL REMAIN THE PROPERTY OF 360 ENVIRONMENTAL. THIS DOCUMENT MAY ONLY BE USED FOR THE PURPOSE FOR WHICH IT WAS COMMISSIONED AND IN ACCORDANCE WITH THE TERMS OF ENGAGEMENT FOR THE COMMISSION. 360 ENVIRONMENTAL DOES NOT HOLD ANY RESPONSIBILITY FOR THE MISUSE OF THIS DOCUMENT.

Figure 1 Site Location

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0 5,000 10,000Meters

4/06/20193238

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GDA 1994 MGA Zone 51

a 10 Bermondsey St, West Leederville, 6007 WAt (08) 9388 8360f (08) 9381 2360w www.360environmental.com.au

@ A41:300,000




2.2 Construction and Operational Details

The proposed Geochemical Survey will not involve the construction of any landforms or

infrastructure and the only operational components will be the driving of a 4wd light vehicle

along existing tracks. There is no proposed clearing or additional disturbances on EP 104

or R1.

2.2.1 Care and Maintenance

No care and maintenance activities are required for the Geochemical Survey sites.

2.2.2 Decommissioning

There is no site infrastructure within the Geochemical Survey lines. Existing tracks will be

utilised for the survey. These tracks are regularly used as pastoral and exploration tracks

and therefore will remain indefinitely. Therefore, no decommissioning works are required

to be undertaken.

2.2.3 Rehabilitation

There is no proposed clearing or disturbance activities as part of the survey. Therefore,

no rehabilitation activities will be required.

2.3 Timeframes and Schedules

Table 4: Timeframes

Item Timeframe Date Responsibility

Geochemical Survey R1 1.5 days Fourth Quarter

of 2019 Gulliver

Geochemical Survey EP

104 1.5 days

Fourth Quarter

of 2019 Gulliver




Description of the Environment

(Regulation 14(2))

This section refers to the existing environment and surrounds of EP 104 and R1 using

historical data and desktop analysis. The Geochemical Survey lines are located within

existing cleared areas where there are no registered Cultural Heritage sites, European

Heritage sites, Threatened flora or fauna or an Environmentally Sensitive Area (ESA).

3.1 Natural Environment

The project areas fall within the Dampierland IBRA region (Department of the Environment

and Energy, 2016). Dampierland is further split into two subregions, Pindanland, and the

Fitzroy Trough. The study areas lie within the Fitzroy Trough subregion. This semi-arid

subregion forms the northern edge of the Canning Basin, comprising the middle and lower

catchments of the Fitzroy River. The Canning Basin is a large, predominantly onshore

sedimentary basin, ranging in age from the early Ordovician (490M years ago) to the

Cretaceous (80M years ago). The Canning Basin is subdivided into a series of troughs,

sub-basins, platforms, shelves and terraces bounded by generally northwest–southeast

trending syn-depositional fault systems (Graham, 2001).

The project areas are situated in the Fitzroy Trough which contains the thickest

sedimentary deposits of the Canning Basin, with inferred depths of up to 15 km. Landforms

of the Fitzroy Trough include alluvial plains from the Fitzroy River, sandstone and eroded

dune surfaces, coastal mudflats surrounding the Fitzroy Delta, Pindan, Boab and Eucalypt

woodlands, with patches of rainforest and hummock grassland on limestone in the north

and east. The total area of the Fitzroy Trough subregion comprises 3,614,096 ha. The

dominant land uses are grazing on native pastures, unallocated crown land and crown

reserves and conservation(Graham, 2001).

3.2 Flora, Vegetation and Fauna

Mapping of the vegetation of Derby was completed on a broad scale (1:100,000) by Beard

(1980) (Department of Primary Industries and Regional Development, 2018). These

vegetation units were re-assessed by Shepherd et al. (2001) to account for clearing in the

intensive land use zone, dividing some larger vegetation units into smaller units. There are

three Beard/Shepherd vegetation units mapped across the sites. The Shepherd

vegetation types are described below (Figure 2).

R1 -

• Fitzroy Sandplains 755 - Pindan with low trees / Acacia thicket with scattered low

trees over spinifex. Acacia eripoda, Corymbia dichromophlia, Triodia pungens,

T.bitextura

• Fitzroy Sandplains 127 - Tidal mud flat.




EP104 -

• Dampierland 750 – Pindan woodland / Acacia thicket with eucalypt woodland over

spinifex. Acacia tumida, Eucalyptus tectifica, Corymbia grandifolia, Triodia pungens,

T.bitextura

Desktop assessments were conducted for the project of the flora and vegetation values

of conservation significance as listed under the EPBC Act. A 10 km buffer was applied to

all searches to ensure all records in the vicinity were highlighted.

The major habitat for fauna in the area is the savannah woodland with dominant trees

including Corymbia, Eucalyptus, Baobab and Acacia. Five reptiles of conservation

significance have the potential to occur in the project area. Eighteen bird species of

conservation significance have the potential to occur in the project area. There are 12

species of terrestrial mammals of conservation significance that have the potential to occur

in the project area (Department of Biodiversity Conservation and Attractions, 2019;

Department of the Environment and Energy, 2019).

Given the Geochemical Survey’s use of existing cleared tracks (i.e. no proposed

clearing/disturbance) and the low impact nature of the proposed activities, no impacts to

the above-mentioned flora or fauna is expected.

3.3 Soils and Land Systems

The survey sites are located on three soil landscape systems; Yeeda System, Carpentaria

system and the Wanganut system (Department of Primary Industries and Regional

Development, 2018). These systems are described below (and shown on Figure 3):

R1 –

• Yeeda System (337Ye) – Red sandplains supporting pindan vegetation with dense

acacia shrubs, scattered bloodwood and grey box trees and curly spinifex and

ribbon grass

• Carpentaria System (337Cr) – Coastal country, bare mud flats and saline soils with

halophytic vegetation.

EP104 -

• Yeeda System (337Ye) – Red sandplains supporting pindan vegetation with dense

acacia shrubs, scattered bloodwood and grey box trees and curly spinifex and

ribbon grass.

• Wanganut System (335Wa) – Sandplains and linear dunes supporting pindan

woodlands with acacias and bloodwoods and curly spinifex-ribbon grass and broad

low lying swales supporting bloodwood-grey box woodlands with curly spinifex-

ribbon grass.




3.4 Hydrogeology

3.4.1 Surface Water

The survey sites are within the Fitzroy River Catchment, which covers approximately

85,000 km2, making it the major river system in the basin. Flows occur between November

and May following the seasonal rainfall. High tides in the Derby area have been recorded

up to ten metres high, requiring high drainage (Figure 4).

As activities will be conducted during the dry season, or prior to the full onset of the wet

season, no disturbance to water flow or sedimentation is expected.

3.4.2 Groundwater

The Canning Basin covers six regional aquifers whose distribution largely determines the

groundwater salinity patter. Major groundwater resources in these aquifers cover

approximately half of the Derby area. Minor fresh groundwater resources cover a further

third of the area and about a tenth of the area is underlain by saline groundwater only, or

by thick non-water-bearing formations. Groundwater provides almost all water used in the

area but has been most intensively developed on the Derby peninsula, primarily from the

Erskine Sandstone. Groundwater abstraction around the town of Derby has led to

saltwater intrusion and a consequent rise in salinity levels.

There are no public drinking water supply areas (PDWSA) that occur at the survey sites,

or within close proximity to the area (Department of Water and Environmental Regulation,

2019).

3.5 Climate

The climate around EP 104 and R1 is classified as tropical with hot, humid summers and

warm winters. The average maximum temperature at Derby ranges from 30.7°C in June

to 38.2°C in November. The mean annual rainfall in Derby is 701.2 mm, with the highest

recorded in January (204 mm) and the lowest occurring in September (1.0 mm). The mean

number of rain days for Derby is 52 days per year, with the majority falling in the months

of December to March.

Plate 3 uses data from Derby Aero, the nearest meteorological station to the survey sites

to illustrate the mean monthly rainfall, mean maximum and mean minimum temperatures

(Bureau of Meteorology, 2019).




Plate 3: Climate Data from the Bureau of Meteorology (2019)

3.6 Heritage

3.6.1 Native Title

Current Native Title claim exists over both project areas. The Native Title claimants at R1

are the Mawadjala Gadjidgar people (WC2011/003). At EP104, the Bindunbur Native

Title Application is registered over the site (WC2015/007) (Department of Planning Lands

and Heritage, 2018).

3.6.2 Aboriginal Heritage

Aboriginal cultural heritage artefacts are records of the past occupation of the land by

Aboriginal People. There is potential for isolated Aboriginal archaeological artefacts or

surface scatters to be located on land within study areas. The Department of Planning,

Lands and Heritage Inquiry System identified a number of Registered and Lodged

Aboriginal heritage sites within the study areas; however these sites will not be impacted

by the proposed surveying activities (Department of Planning Lands and Heritage, 2018)

(Figure 6).

The sites are listed in Table 5 below.

0

5

10

15

20

25

30

35

40

45

0

50

100

150

200

250

Tem

per

atu

re ˚

C

Rai

nfa

ll m

m

Month

Long-term Average Rainfall Mean maximum temperature

Mean minimum temperature




Table 5: Aboriginal Heritage Sites – Lodged and Registered

Site ID Name Site Type Type Location

17,099 TEA04 Lodged Shell Within 5km of survey

tracks in R1

17,097 TEA01 Lodged Midden/Scatter, Shell Within 5km of survey

tracks in R1


tracks in R1


tracks in R1

17,443 Meda Dune Registered

Site

Artefacts/Scatter.

Grinding

patches/Grooves

Located approximately

1.5km SW of West-

Kora 1

13,240 Derby

Leprosarium

Registered

Site

Ceremonial, Modified

Tree, Mythological

Located approximately

1.5km SW of West-

Kora 1

3.6.3 European Heritage

There are no State Heritage places identified within the study area (State Heritage Office,

2019).

3.7 Socio-economic Environment

The survey areas are located within the Shire of Derby/ West Kimberley, which has a total

population of approximately 7,705 people (Australian Bureau of Statistics, 2016). The

town of Derby is the closest population centre to the sites; located approximately 20 kms

south-west of R1 study area, and approximately 50 kms south-east from EP 104. The

mineral and pastoral industry are important contributors to the local economy, with

approximately 34 pastoral leases registered in the shire (Australian Bureau of Statistics,

2016).

As R1 is situated in the Meda Station pastoral lease, pastoral activities may be conducted

within the area. There are also two existing well heads; Stokes Bay-1 and Point Torment-

1. There is a plugged and abandoned well, Padilpa-1, located on EP104.

The proposed surveying activities will not interfere with any approved activities in the area.

3.8 Values and Sensitivities

Based on the DMIRS Guideline for the Development of Petroleum and Geothermal

Environment Plans in Western Australia (DMIRS 2016), factors considered to be sensitive

include:

• Areas of protected of rare or endangered flora and fauna




• Areas of significant habitat (including wetlands and mangroves)

• Areas of temporal significance (including breeding grounds, migration routes and

resting and aggregation areas)

• Cultural and heritage sites

• Marine and terrestrial protected areas

• Groundwater.

Desktop and database searches were used to identify any sensitive or locally or regionally

important areas that may be affected by the activities and events in this scope of work.

The survey areas are not located within any known Environmentally Sensitive Areas

(ESAs), the closest ESA is 25 km north-west of EP104 survey areas. The survey sites are

not located within any areas of significant wetlands or mangroves, the nearest important

wetland is 20 km north-east of the R1 survey area. There are no recorded cultural or

heritage sites within the survey areas, nor are there any protected or conservation areas

and the proposed activities will not interfere with groundwater.




Environmental Risk Assessment and

Management (Regulation 14(3))

This section provides details of the potential environmental risks arising from the proposed

Geochemical Survey and how Gulliver will manage these risks. Gulliver has undertaken

consultation with the relevant stakeholders to determine any perceived risks associated

with the activities.

4.1 Risk Assessment Methodology

This risk assessment process has been applied to the proposed Geochemical Survey based

on the principles of AS/NZA ISO 31000:2009 Risk Management – Principles and

Guidelines. The risk assessment process is composed of three key steps:

• Risk Identification – identify and document environmental risks and impacts

associated with the organisation activities, goods and services with the use of the

hierarchy control measures

• Qualitatively ranking potential environmental risks to establish relative significance

• Establishing and documenting risk treatments to mitigate potentially significant

environmental impacts.

All components of the Geochemical Survey relevant to the scope of this EP are detailed in

Section 2. The Qualitative Risk Rating Matrix, along with the corresponding descriptions

of consequence and likelihood levels can be seen in Tables 6, 7, 8 and 9.

4.2 Identification of Sources of Risk and

Associated Impacts

The environmental risk assessment process identifies aspects of the proposed

Geochemical Survey activities that poses an inherent risk (risk pathway), identifies

potential impacts arising from the risk pathway and assigns a ranking to the inherent risk.

Control measures are then identified for each inherent risk to ensure it is an ‘As Low As

Reasonably Practicable’ (ALARP) level. Following implementation of the control

measures, a residual risk ranking is applied. Refer to Table 9 for the risk assessment

results.

In some circumstances, the initial risk may be extremely low or negligible and may not

require any treatment options. In circumstances where there are existing standards or

practices that apply to environmental risks, they will be used as appropriate risk treatment.

4.3 Justification of ALARP and Acceptability

The well-established principle of ALARP has been implemented during the Risk

Assessment process for EP104 and R1. DMIRS considers the following definition to be

used to determine whether a risk has been lowered to ALARP:




If a measure is practicable and it cannot be shown that the cost of the measure

(in money, time and effort) is grossly disproportionate to the benefit gained; then

the measure is considered reasonably practicable and should be implemented.

The criterion is “reasonably practicable” not “reasonably affordable”: justifiable

cost and effort is not determined by the budget constraints/viability of a project.

When determining risk treatment to reduce a risk to ALARP, the hierarchy of risk controls

summarised below has been considered:

• Avoidance or Elimination: where reasonable and practicable, eliminate the risk. This

can be done by removing or avoiding the activity that posed the risk

• Substitution: reduce the risk by substituting a different activity which poses a lower

risk

• Separation: limit the risk by isolating the activity that poses a risk

• Engineering: control the risk with an engineered solution

• Administrative: mitigate the risk using administrative procedures.




Table 6: Qualitative Risk Rating Matrix

Consequence

Likelihood 1. Insignificant 2. Minor 3. Moderate 4. Major 5. Catastrophic

5. Almost Certain L H H E E

4. Likely L M H E E

3. Possible L M M H H

2. Unlikely L L M M H

1. Rare L L L M M

Table 7: Likelihood Classification

Likelihood Frequency Probability

ALMOST CERTAIN Occurs more than once per year The event is expected to occur at some time as there is a history of continuous occurrence with similar

projects/activities 91-100%

LIKELY Typically occurs once or twice per year There is a strong possibility the event will occur as there is a history of frequent occurrence with similar

projects/activities. 61-90%

POSSIBLE At least once in 3 years The event might occur at some time as there is a history of infrequent occurrence of similar issues with similar

projects/activities. 41-60%

UNLIKELY At least once in 10 years Not expected, but there’s a slight possibility it may occur at some time. 11-40%

RARE Once in 15 years Highly unlikely, but it may occur in exceptional circumstances. 0-10%

Table 8: Consequence Classification

Environmental Factor INSIGNIFICANT MINOR MODERATE MAJOR CATASTROPHIC

Biodiversity/Flora/ Fauna/Ecosystem

Alteration or disturbance to an

isolated area that is unlikely to

affect the habitat species or

ecosystem

Alteration or disturbance to less

than 5% of a habitat, species or

ecosystem resulting in a minor,

recoverable impact within 1 year

Alteration or disturbance to 5-30%

of a habitat, species or ecosystem

resulting in a moderate,

recoverable impact within 1-2

years

Alteration or disturbance to 30-

70% of a habitat, species or

ecosystem result in in a major,

recoverable impact within 3-10

years

Alteration of more than 70% of a

habitat, species or ecosystem

resulting in an extinction or

permanent change or reduce

threshold level below 30%.

Recovery, if possible is greater

than 10 years

Water Resources

Negligible impact to site area and

no effect to the use of water

Contained low impact with

negligible effect on the use of the

water

Uncontained impact that will affect

the use of the water but can be

remediated in the short term

Extensive hazardous impact that

requires long term remediation

Uncontained hazardous impact

with residual effect, even with long

term remediation




Environmental Factor INSIGNIFICANT MINOR MODERATE MAJOR CATASTROPHIC

Land Degradation

Negligible impact to isolated area Contained low impact, not

impacting on any environmental

value

Uncontained impact, able to be

rectified in short-term without

causing pollution or contamination

Extensive hazardous impact on an

environmental value requiring long-

term remediation

Uncontained hazardous impact


term remediation

Air Quality

No Detectable impact Contained low impact not

impacting on any environmental

value

Uncontained impact that will

impact on an environmental value,

but able to be remediated in short

term

Extensive hazardous impact on an

environmental value that requires

long term remediation

Uncontained hazardous impact on

one or more environmental values


term remediation

Rehabilitation

Site is safe, stable and non-

polluting and does not significantly

impact the post drilling land use

The site is safe, all major landforms

are stable and any stability or

pollution issues are contained and

require no residual management.

Post drilling land use is not

compromised significantly.

The site is safe and any stability or

pollution is\sues require minor,

ongoing maintenance by end land-

user

The site cannot be considered

safe, stable or non-polluting

without long-term management.

Agreed end land-use requires

ongoing management

The site is unsafe, unstable and is

causing pollution or contamination

that will cause an ongoing residual

impact. The post drilling land use

cannot be achieved

Table 9: Risk Assessment

Activity Risk Pathway Impacts Inherent Controls Residual

Likelihood Consequence Risk Likelihood Consequence Risk

Movement of vehicles within the survey sites and access roads

Fauna / vehicle interaction

• Injury or death of native fauna • Disturbance of habitat during site

works

Possible Minor M

• Site induction relating to fauna management and safety

• Adhering to vehicle speed limits

• Being aware of roadside hazards, avoid where possible, driving at dusk, dawn and night.

• Driving on existing designated tracks only • GPS to ensure driver is in the correct area

Unlikely Minor L

Interaction with native vegetation

Damage to native vegetation and flora Unlikely Minor L

• Site induction raising relating to flora management and safety

• Driving on existing designated tracks only • GPS to ensure driver is in the correct area

Rare Minor L

Introduction or spread of weeds

• Decline in condition of vegetation and fauna habitat

• Invasive species

Possible Minor M

• Site induction relating to awareness of weeds

• Vehicle check when mobilising and demobilising to sites

• Adhering to weed and hygiene inspection procedure RLS_EMS_PRO_001

• Brushing down vehicle • Driving on existing designated tracks only

Unlikely Minor L




Activity Risk Pathway Impacts Inherent Controls Residual

Likelihood Consequence Risk Likelihood Consequence Risk

Spill/loss of hydrocarbons from vehicle

• Localised contamination of soil or surface water

• Impacts to vegetation and flora from spills

Unlikely Minor L

• Site induction relating to hydrocarbon spills response

• Adhering to Rey’s Spill Response Procedure RLS_CMS_PRO_011

• Adhering to Waste procedure • Spill kit located on vehicles

• Vehicle pre-starts • No driving of vehicles along track portion located in

the tidal areas (walking only)

Rare Minor L

Fire ignition source from vehicles, or personnel

Bushfire sparked leading to loss of native flora and fauna habitat

Unlikely Moderate M

• Site induction raising awareness relating to fire risk • Adhering to Emergency Response Procedure

RLS_CMS_PRO_006

• Fire extinguisher located on all vehicles

Rare Moderate L

Dust generation from vehicles on unsealed roads/tracks

• Decline in health of vegetation • Disturbance to landowners

Unlikely Minor L • Adhering to speed limits

• Driving to road conditions • Complaints register

Rare Insignificant L

Soil Sampling

Interaction with surrounding land users or livestock

Shallow depressions from sampling methods Unlikely Insignificant L • Ensure the minimum amount (20 cm / 200-300

grams) of soil is collected Rare Insignificant L




Objectives, Standards and

Measurement Criteria (Regulation 14(5))

The environmental performance objectives, standards and measurement criteria of this EP

have been derived from the environmental risk assessment completed in Section 4.

This section provides a measurement of performance for Gulliver to ensure the protection

of the environment. The S.M.A.R.T (Specific, Measurable, Achievable, Relevant and

Timely) principles have been applied to each objective and are summarised in Table 10

below.




Table 10: Environmental Performance Objectives, Standards and Measurement Criteria

Risk Pathways Environmental Performance Objective Environmental Performance Standards Measurement Criteria

Fauna/vehicle interaction No injury or death of native fauna

attributed to vehicle strikes

All personnel to have undertaken Gulliver’s site induction which includes

details relating to fauna management and safety.

Risks to fauna from vehicle strike will be minimised by adhering to

Gulliver/Rey’s Road Travel Management Procedure

(RLS_SMS_PRO_003):

• Minimising night driving • Adhering to vehicle speed limits

• Being aware of roadside hazards present by animals particularly when driving at dusk, dawn and night.

Audit/Inspection register (RLS_CMS_REG_008) and report will show no incidents

of injury or death of native fauna attributed to vehicle collisions

The Induction and Training Register will demonstrate that all personnel and

contractors involved in the surveying activities have completed the site induction

which includes fauna management and safety and vehicle access and speed limits.

Interaction with native

vegetation

No unplanned loss of or damage to

native vegetation or flora


details relating to fauna management and safety.

Adhering to existing tracks only

Audit/Inspection register (RLS_CMS_REG_008) and report will show there were

no incidents of unplanned loss of or damage to native vegetation or flora

Gulliver’s Induction and Training Register (RLS_CMS_REG_006) will demonstrate

that all personnel and contractors involved in the surveying activities have

completed the site induction which includes flora management.

Introduction or spread of

weeds

No unnatural spread of existing

weeds as demonstrated by all vehicle

having undergone a biosecurity

hygiene inspection

Staff trained in awareness and understanding of spread of weeds

Vehicle brush-down and inspection prior to mobilising and demobilising

from the sites will be undertaken

The Induction and Training Register (RLS_CMS_REG_006) will demonstrate that all

personnel and contractors involved in the surveying activities have completed the

site induction which includes details relating to awareness and understanding of the

spread of weeds

Motor Vehicle Inspection Form (RLS_SMS_FRM_001) will show that all vehicles

were brushed down before mobilising and demobilising site

No records of weeds in Environmental Impacts and Aspects Register

(RLS_EMS_REG_001)

Spill / loss of hydrocarbons

from vehicle

No loss of containment of

hydrocarbons during survey


an understanding of spill management.

A spill kit will be readily available in the service vehicle in accordance

with Rey’s Spill Response Procedure (RLS_EMS_PRO_011_Rev 1)

Any clean up, control and containment of hazardous spills will be dealt

with in accordance with Rey’s Spill Response Procedure

Any contaminated material will be recovered and/or disposed of off site

Vehicle and machinery pre-start check – including a check of all fuel

hoses and couplings to ensure they are in good condition and not leaking



which includes details relating to spill management as well as having undergone

familiarisation/training with the Emergency Response Procedure for the site.

Inspection records to confirm there is no evidence of spills which have not been

responded to

Waste records confirms that waste generated from spill events are segregated

appropriately and disposed of by a suitably licensed contractor.

Any spills or leaks that do occur are promptly contained and remediated (evidence

recorded in incident reports)

Motor Vehicle Inspection Form (RLS_SMS_FRM_001) will be recorded in registers

and show pre-starts undertaken before every use

Fire ignition source from

vehicles or personnel

No fires sparked from activities on the

site.


an understanding of fire management






Risk Pathways Environmental Performance Objective Environmental Performance Standards Measurement Criteria

In the event of a fire, minimise the

impact of fire through the use of fire-

fighting equipment as outlined in the

SMS

Training will be conducted in accordance with the Emergency Response

Procedure (ERP) that describes initial actions, reporting requirements

and evacuation procedures.

All vehicles to be fitted with a fire extinguisher

which includes an understanding of fire management on site, as well as having

undergone familiarisation/training with the ERP for the site.

Training records confirm that personnel are aware of the initial actions, reporting

requirement and evacuation and assembly requirements in response to a fire event.

Audit and inspection records will demonstrate all vehicles contain a fire

extinguisher.

Dust generation from

vehicles on unsealed

roads/tracks (disturbance

to landowners)

No complaints from landowners in

relation to dust emissions generated

by the activity

Rey will record all complaints with regard to dust emissions in the Event

and Feedback Register [RLS_CMS_REG_002_Rev_0]) that includes the

following information:

• The details of complaints received concerning dust

• Any action taken in response to the complaint.

Annual Performance report verifies any dust complaints have been appropriately

managed with relevant details recorded in the Event and Feedback Register

[RLS_CMS_REG_002_Rev_0]).

Dust generation from

vehicles on unsealed

roads/tracks (health of

vegetation)

The generation of dust from vehicles travelling on unsealed roads / tracks is well understood and as such control measures for managing such a risk are also well understood across the industry.

The risk of this type of event is considered to be low given the low number of vehicles and short duration of on-site activities. The amount of dust generated is considered negligible.

Consequently, Gulliver do not believe that dust generation from care and maintenance activities covered under this plan will result in any health impacts to vegetation thus has not considered this

further.




Legislation and Other Requirements

(Regulation 14(6))

6.1 Legislation

The Petroleum and Geothermal Energy Resources Act 1967 (PGER Act) provides

regulatory jurisdiction to DMIRS for exploration and development of all onshore petroleum

resources in Western Australia. The PGER Act regulates all onshore petroleum operators

to ensure they meet the applicable Commonwealth and State environmental laws and

regulations.

6.1.1 State Legislation

They key State Legislation applicable to this EP includes:

• Petroleum and Geothermal Energy Resources Act 1967 (PGER Act)

• Petroleum and Geothermal Energy Resources Regulations 2012 (PGERR)

• Petroleum and Geothermal Energy Resources (Environment) Regulations 2012

(PGER(E)R)

• Schedule of Onshore Petroleum Exploration and Production Requirements

1991(Onshore Schedule)

• Environmental Protection Act 1986 (EP Act)

• Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)

• Environmental Protection (Clearing of Native Vegetation) Regulations 2004

(Clearing Regulations)

• Aboriginal Heritage Act 1972 (AH Act)

• Biodiversity Conservation Act 2016 (BC Act).

• Contaminated Sites Act 2003 (CS Act)

• Rights in Water and Irrigation Act 1914 (RIWI Act).

6.1.1.2 Petroleum and Geothermal Energy Resources Act

The DMIRS regulates petroleum and geothermal activities under the following

environmental regulations:

• PGER Act

• Petroleum (Submerged Land) (Environmental) Regulations 2012

• Petroleum Pipelines (Environmental) Regulations 2012.

The purpose of these regulations is to ensure petroleum or geothermal activity is carried

out in a manner consistent with the principles of ecologically sustainable development and

in accordance with an EP that:




• Demonstrates the environmental impacts and risks of the activity will be reduced to

ALARP

• Has appropriate environmental performance objectives and environmental

performance standards

• Has appropriate measurement criteria for determining whether objectives and

standards have been met.

Gulliver is required to submit an EP to DMIRS and attain approval under the PGER Act,

as enforced under the PGER(E)R, prior to commencing activities associated with the oil

and gas survey.

6.1.1.3 Schedule of Onshore Petroleum Exploration and Production

Requirements 1991

The Onshore Schedule outlines the legislative requirements for conducting onshore

petroleum site inspection activities in Western Australia. The purpose of the schedule is

to ensure activities are conducted in a professional, safe and environmentally responsible

manner. Gulliver will abide by all relevant aspects of the Onshore Schedule throughout the

oil and gas geochemical survey.

6.1.1.4 Environmental Protection Act 1986

The Environmental Protection Act 1986 (EP Act) Act oversees the prevention, control, and

abatement of pollution and environmental harm, for the conservation, preservation,

protection, enhancement, and management of the environment.

Under the EP Act, the regulations that apply to this EP include the Environmental

Protection Regulations 1987, Environmental Protection (Controlled Waste) Regulations

2004, Environmental Protection (Clearing of Native Vegetation) Regulations 2004.

6.1.1.5 Aboriginal Heritage Act 1972

The Aboriginal Heritage Act 1972 (AH Act) ensures protection for places and objects in

Western Australia that are significant to Aboriginal people and their cultural connections.

These places and objects are recognised as Aboriginal Heritage Sites (DPLH 2018) and

are protected under AH Act, requiring approvals under Section 18 to disturb a registered

site.

There are four lodged sites within the R1 survey area their ID numbers are as follows;

17095, 17096, 17097, 17099. They are not within the vicinity of the survey areas.

6.1.1.6 Biodiversity Conservation Act 2016

The Biodiversity Conservation Act 2016 and the Biodiversity Conservation Regulations

2018 provide protection for biodiversity, with a focus on matter regarding threatened

ecological communities and threatened flora and fauna species (DBCA 2018).

There are no potential impacts to threatened flora and/or fauna within the survey area,




6.1.1.7 Contaminated Sites Act 2003

The Contaminated Sites Act 2003 (CS Act) oversees the identification, management and

remediation of contaminated sites. The CS Act requires known or suspected

contamination to be reported to DWER, investigated and if necessary, remediated.

There are no known contaminated sites recorded within the survey area, however if any

contamination is encountered, it will be reported to DMIRS and DWER and managed

accordingly.

6.1.1.8 Rights in Water and Irrigation Act 1914

The Rights in Water and Irrigation Act 1914 (RIWI Act) governs rights in water resources,

provision for the regulation, management, use and protection of water resources and for

related purposes.

Both sites are located within the Canning-Kimberley groundwater proclamation area, and

are not located in a Surface Water Proclamation Area. No water is proposed to be

abstracted as part of the Geochemical Survey.

6.1.2 Commonwealth Legislation

The relevant Commonwealth legislation that may apply to the survey areas are:

• Native Title Act 1993 (NT Act)

• Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)

• National Greenhouse and Energy Reporting Act 2007 (NGER Act)

• Aboriginal and Torres Strait Islander Heritage Protection Act 1984.

6.1.2.1 Native Title Act 1993

Under the Native Title Act 1993 (NT Act) Native Title is extinguished on freehold land that

has been granted on or before 23 December 1996.

6.1.2.2 Environment Protection and Biodiversity Conservation Act

1999

Under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act),

an ‘action’ requires the approval of the Commonwealth Minister for the Department of the

Environment and Energy (DoEE) if the action has, will have or is likely to have significant

impact on any of the following Matters of National Environmental Significance (MNES).

• World Heritage properties

• National Heritage places

• Ramsar wetlands of international importance

• Nationally threatened animal and plant species and ecological communities

• Migratory species protected under international agreement s

• The Great Barrier Reef Marine Park

• Commonwealth marine environment




• Nuclear actions

• A water resource, in relation to coal seam gas development and large coal mining

developments.

There are currently no known MNES in the survey areas that may be affected by the

proposed activities.

6.2 International Conventions and Agreements

The international conventions and agreements that are relevant to onshore surveying

include:

• Convention on the Conservation of Migratory Species of Wild Animals 1983

(commonly known as the Bonn Convention)

• Agreement between the Government of Australia and the Government of Japan for

the Protection of Migratory Birds and Birds in Danger of Extinction and their

Environment (commonly referred to as the Japan Australia Migratory Bird

Agreement (JAMBA)).

• Agreement between the Government of Australia and the Government of the

Republic of Korea on the Protection of Migratory Birds (commonly referred to as the

Republic of Korea Australia Migratory Bird Agreement (ROKAMBA))

• Convention on Wetlands of International Importance Especially as Waterfowl

Habitat (Ramsar Convention)

• Vienna Convention for the Protection of the Ozone Layer and the Montreal Protocol

on Substances that Deplete the Ozone Layer.

• Basel Convention on the Control of Transboundary Movements of Hazardous

Wastes and their Disposal.

The proposed survey will not significantly impact migratory birds, wildlife or wetlands. Any

hazardous or other wastes generated will be disposed of off-site at appropriate facilities

within the State.

6.3 Australian Standards

The Codes of Practice that apply to the site inspection activities include AS 1678:

Emergency Procedure Guide and ASNZS ISO 31000:2009 Risk Management.

6.4 Codes of Practice

The industry code of practices that apply to the survey activity is the Australian Petroleum

Production and Exploration Association (APPEA) Code of Environmental Practice

(APPEA 2008).

The objectives of the APPEA are summarised as follows:

• To avoid disturbance of sites of cultural heritage significance where practicable and

reduce the risk to cultural heritage values to ALARP and to an acceptable level




• To reduce the impacts on soils and surface drainage to acceptable levels and to

reduce the risk of impact to ALARP

• To reduce the impacts to vegetation and wildlife habitats to acceptable levels and to

reduce the risk of impact to ALARP

• To reduce the risk of introduction (or spread) of weeds, pests and pathogens to

ALARP and to an acceptable level

• To reduce the impact on other land users to an acceptable level and to reduce the

risk of impact to ALARP

• To reduce the impact of noise, light, odours, traffic and vibration to an acceptable

level and to reduce the risk of impacts to ALARP

• To reduce the volume of waste produced to ALARP and to an acceptable level.

Ensure that relevant wastes are disposed of in appropriate facilities

• To reduce the visual impacts of seismic survey operation to ALARP and to an

acceptable level

• To discourage third party access following completion of operation to ALARP and to

an acceptable level

• To reduce greenhouse emissions to ALARP and to an acceptable level.

Gulliver has considered this code of practice in the development of this EP and will adhere

where applicable for the proposed low-impact survey.

6.5 Other Requirements

The survey areas are not within any managed conservation or national park areas nor

within a defined ESA.

6.6 Referrals to other Government Agencies

This EP has considered the above legislation and due it’s low impact nature, it should not

require any referrals, permits or licenses relevant to the environmental management of the

activity. There is no proposed clearing of vegetation and the proposed activities would be

exempt under Regulation 5, Item 24 – Clearing under a Petroleum Act of the Environmental

Protection (Clearing of Native Vegetation) Regulations 2004, which allows clearing for

exploration approved under various Petroleum Acts.




Implementation Strategy (Regulation 15)

The implementation strategy ensures that environmental impacts and risks associated with

the Geochemical Survey activities are continuously reduced to ALARP and that the

environmental performance objectives and standards established in Section 5 of this EP

are met.

7.1 Systems, Practices and Procedures

This section details the proposed practices, management strategies, procedures and

mitigation measures that Gulliver and their contractors will implement to ensure all

potential environmental impacts and risks associated with the well sites geochemical

survey remain ALARP and that all legal and corporate obligations are met.

Since Gulliver is a subsidiary of Rey Resources, Gulliver falls under Rey’s Integrated

Management System Manual (IMSM) (Appendix B). Under this IMSM, Gulliver’s

Corporate Environmental Policy and Safe Management System (SMS) is linked to Rey’s

SMS. Gulliver’s SMS has recently been accepted by DMIRS Dangerous Goods and

Critical Risks Directorate (Ref: P0025/201801).

The IMSM provides for various management plans and procedures that Gulliver will be

guided by (Table 11).

Table 11: Gulliver Integrated Management System

Manuals and Policies

RLS_IMSM Integrated Management System Manual

RLS_SMSM Health and Safety Management System Manual

GP_SMSM Safety Management System (Gulliver)

RLS_CMS_POL_001 Corporate Policy Statement

RLS_CMS_POL_002 Safety Policy Statement

RLS_EMS_POL_001 Environment Policy Statement (Rey)

GP_CMS_POL_001 Corporate Health and Safety Policy (Gulliver)

Management Plans

RLS_CMS_MPL_001 Stakeholder Engagement Plan

RLS_SMS_MPL_001 Health and Safety Management Plan

Procedures

RLS_CMS_PRO_001 Document and Record Control Procedure

RLS_CMS_PRO_002 Monitoring and Measuring of Performance Procedure

RLS_CMS_PRO_003 Communication and Consultation Procedure

RLS_CMS_PRO_004 Internal Audit and Inspection Procedure

RLS_CMS_PRO_005 Hazard and Risk Management Procedure

RLS_CMS_PRO_006 Emergency Response Procedure

RLS_CMS_PRO_007 Event and Feedback Reporting and Investigation Procedure

RLS_CMS_PRO_008 Contractor Evaluation Procedure

RLS_CMS_PRO_009 Induction and Training Procedure





RLS_CMS_PRO_010 Review of Legislation and Compliance Procedure

RLS_CMS_PRO_011 Spill Response Procedure

RLS_CMS_PRO_012 Job Safety and Environment Analysis (JSEA) Procedure

RLS_SMS_PRO_001 Fitness for Work Procedure

RLS_SMS_PRO_002 Return to Work Procedure

RLS_SMS_PRO_003 Road Travel Management Procedure

RLS_SMS_PRO_004 Isolation and Tag out Procedure

RLS_EMS_PRO_001 Hygiene and Weed Inspection Procedure

RLS_EMS_PRO_002 Vegetation Line Clearing Procedure

RLS_EMS_PRO_004 Rehabilitation Procedure

As per Section 5, the above management measures and systems are used to measure

environmental performance and criteria to ensure all proposed activities are conducted in

an ALARP manner.

7.2 Corporate Environmental Policy

A copy of Rey’s corporate environmental policy is provided in Appendix A.

7.3 Roles and Responsibilities of Personnel

To meet the requirements of Regulation 15 of the PGER(R), a clear Chain of Command

for the implementation of the petroleum activity is outlined in Plate 4. Detailed roles and

responsibilities are further described in Section 7.3.1.

Plate 4: Chain of Command




7.3.1 Roles and Responsibilities

This EP and its commitments and controls will be implemented and managed by Gulliver.

In accordance with this EP, the site activities will be conducted in the field under the

supervision of a supervisor or approved delegate. Detailed roles and responsibilities of key

personnel for the identified management strategies are defined in Table 12.

Table 12: Roles and Responsibilities

Role Responsibility

Gulliver/Rey

Managing

Director (or

delegate)

Ensure the EP is implemented to the satisfaction of the DMIRS and in

accordance with all legal requirements.

Provide resources for the effective implementation of this EP

Identify and support implementation of risk-based environmental

improvement plans

Ensure appropriate and effective emergency response capability

Facilitate communication with company personnel, government and the

public in the event of an incident and undertakes full investigation of the

incident.

Ensure all personnel receive environmental training, induction and

awareness programs applicable to their position.

Update and maintain induction materials and records.

Conduct or coordinate and review environmental audits to assess

compliance with environmental requirements.

Undertake internal auditing on completion of care and maintenance and

clean-up activities.

Undertake internal and external reporting requirements.

Operations

Manager

Implement this EP and ensure compliance with the EP as relates to the care

and maintenance activities for the well sites.

Ensure that Gulliver and contracting company’s environmental procedures

and emergency response procedures are communicated and understood by

all personnel.

Ensure appropriate induction and environmental education of the workforce.




Role Responsibility

Maintain clear communications between Gulliver and the workforce.

Ensure that Gulliver and the contractor’s work procedures are compliant

with this EP

Ensure site inspections are carried out as required.

Ensures emergency response and spill response is carried out in

accordance with this EP and relevant procedures.

Report incidents immediately to Gulliver (e.g. all spills of hydrocarbons

and/or chemicals)

Ensure procedures are carried out correctly.

Ensuring that consultation with elected Health and Safety Representatives,

committees and employees is maintained as applicable.

Gulliver

Personnel &

Contractors

Effectively apply work procedures.

Actively seek and participate in appropriate training and induction.

Identify hazards and encourage improvement and risk reduction wherever

possible.

Immediately report any incidents or near misses to supervisor.

7.4 Training and Competencies

Rey’s HSE induction addresses all environmental matters and will be provided to all

Gulliver employees and contractors, prior to commencing work. Environmental induction

training of the workforce will include:

• Information referred to in the RLS Induction and Training Procedure

(RLS_CMS_PRO_009)

• Knowledge of the relevant environmental legislation and responsibilities.

The environmental induction will include an overview of environmental matters and the

appropriate management procedures relating to surveying. This includes information on

the following:

• Inspections and audits

• Incident reporting

• Aboriginal heritage

• Significant fauna – including conservation significant species relevant to the activity




• Surface water

• Hydrocarbon and chemical management

• Hydrocarbon and chemical spills management

• Waste management

• Bushfire control.

A checklist for competencies and training will be prepared for the site personnel,

employees and contractors. This will include project specific training such as induction and

‘fit for work’ declarations, general training will be considered a pre-requisite of

engagement in the role and other role specific competencies. The checklist will be

completed for each member involved in the project and reviewed by the respective

manager should they meet all the requirements of the position before commencing work.

Certificates and/or proof of completion will be recorded in RLS Integrated Management

System and RLS Health and Safety Management System. This system allows Gulliver and

their contractors to ensure each employee has the appropriate competencies and training

for their specific responsibilities on site.

Operators and employees will be made aware of the Spill Response Procedure outlined in

Section 8 and will undertake a testing exercise as outlined in Section 8.1.1.

7.5 Monitoring, Auditing, Management of Non-

Conformance, and Review

Environmental monitoring and auditing will be undertaken by Gulliver in accordance with

the PGE(E)R and the Onshore Schedule, and the Schedule of Geothermal Exploration and

Production Requirements 2009. In addition, the requirements under the PGER Act.

Gulliver commits to participating regularly in internal monitoring, auditing and inspections

to assess environmental performance and compliance, and to review the effectiveness of

the environmental management system.

7.5.1 Monitoring

Monitoring and inspections will be undertaken on a routine and opportunistic basis for

reporting requirements include the following:

• Unplanned impacts (incidents) outside of routine operations

• Planned impacts

• Routine site inspections carried out by contractors crosschecking procedures, forms

and schedules where appropriate, to ensure all mitigation measures and

implementation strategies are being upheld and implemented on site.

7.5.2 Auditing & Management of Non-Conformance

Internal environmental auditing is required under Regulation 15(6) of the PGE(E)R, which

requires operators to have an EP that contains an implementation strategy that includes

monitoring, auditing and management of non-compliance and performance. Results from




these audits will be used in the annual or closeout reporting for the activity, to demonstrate

compliance with the approved EP. Auditing of the geochemical survey will be undertaken

by Gulliver’s Operations Manager or delegate in accordance with Gulliver’s Audit and

Inspection Procedure (RLS_CMS_PRO_004).

During the audit, the findings will be recorded on the Internal Audit and Inspection

Observation Form (RLS_CMS_FRM_004) by the auditor. Upon completion of the audit,

the auditor is required to review the findings and categorise each item under one of the

following:

• Major non-conformance – A non-conformance that indicates an aspect of the

management system is non-existent or not being utilised, may affect the services

provided to clients, or multiple instances of the same minor non-conformance

indicating a systematic failure. Issues must be rectified within 30 days

• Minor non-conformance – A non-conformance that is not likely to cause the failure of

the management system, or a single observed lapse in procedures or processes.

Issues must be rectified within 90 days

• Observation – A situation or condition of an aspect of the management system that

may be weak, cumbersome, redundant or overly complex. Observations do not

require action, however should be taken seriously by management to allow for

continual improvement in the process.

7.5.3 Review

An audit summary report will be prepared by the internal auditor, using the official Internal

Report Form (RLS_CMS_FRM_003). The summary should comment generally on the

degree of conformance identified, itemise any findings raised during the audit, and at the

auditor’s discretion, make recommendations for corrective action and/or improvements.

The audit summary report shall be discussed with management and be retained and filed

appropriately. Further information raised within the audit summary meeting or report may

then be entered into the Event and Feedback Register (RLS_CMS_PRO_007).

7.6 Record Keeping

Gulliver will manage a number of internal auditing and reporting systems for relevant

activities undertaken within the well sites and surrounding infrastructure during surveying

and mobilisation. These include:

• Induction and Training Register (RLS_CMS_REG_006)

• Audit and Inspection Register (RLS_CMS_REG_008)

• Event and Feedback Register (RLS_CMS_REG_002)

• Stakeholder Engagement Register (RLS_CMS_REG_007)

• RLS Internal Auditing Reports

o Internal Auditing Report Form (RLS_CMS_REG_003)

o Event and Feedback Report Form (RLS_CMS_REG_002).




7.7 Details of Chemicals and Other Substances

No chemicals or other substances will be used during the Geochemical Survey.




Oil Spill Contingency Plan (Regulation

15(10))

No drilling is proposed at the site and therefore an Oil Spill Contingency Plan (OSCP) is

not required.

The only potential hydrocarbon spill risk is from the fuel tank of the light vehicle. Pre-start

inspections of the vehicle will be undertaken before every use and spill kits will be provided

on the vehicle and all personnel will be inducted before entering site to ensure hydrocarbon

management and safety (refer Section 5).

If a hydrocarbon spill occurs, the Spill Response Procedure (RLS_CMS_PRO_011_Rev_1)

will be followed (Appendix C).

8.1 Credible Spill Scenario

The maximum fuel tank capacity of the light vehicle is 180 litres of diesel fuel. All re-

fuelling will be undertaken offsite and at a commercial fuel station in Derby. Therefore,

the only credible spill scenario is a diesel spill whilst accessing the site and the maximum

credible volume is 180 litres (~0.2m³).

It is extremely unlikely that the entire tank of fuel will spill at one time. The dirt/gravel

tracks are relatively well maintained and are likely to absorb a large majority of the spill

before it flows from the impact site. Portions of the tracks extend into the mud tidal flat

areas; the operator will walk these portions of the tracks to avoid spills in the tidal areas

(Figure 1). Additionally, activities will not be undertaken during cyclone or rainy seasons

nor during high tide events, so the potential for a spill to travel much further from the

impact zone is minimal. Given this, the maximum credible scenario extent of a spill is not

expected to exceed 5-6 m² and to a depth of 200-300 mm. Therefore the approximate

clean up volume required would be 11 m³.

8.1.1 Testing the OSCP

Testing of the oil spill response procedure (or OSCP) will include a desktop exercise prior

to any Geochemical Survey being undertaken (i.e. when introduced). The testing exercise

will include contacting the nominated third-party contacts and emergency services to

ensure their details are correct, to confirm their availability, and to debrief them of the

required spill response (timing, locations, machinery, expertise etc.). The exercise will also

test the details of regulators (DMIRS) to ensure they are the correct and most up to date

details for reporting requirements.

8.2 Spill Response Procedure

Gulliver’s spill response procedure is outlined in detail in Appendix C. Definitions of spill

levels (minor, moderate, major) are outlined in Appendix C. The maximum credible spill




scenario for the Geochemical Survey would require a ‘Minor to Moderate Spill’ response

which is as follows:

• Personnel must immediately obtain the emergency response clean ‐

up/containment kit

• Contain spread by constructing a bund around the spill area (i.e. with rocks or

sand)

• For ground spills, use spill kit material to absorb maximum amount of fluid possible,

then transfer fluid soaked materials into plastic contaminated waste bags

• Use a shovel to dig up and remove any contaminated sand, gravel or rocks and

also transfer into plastic contaminated waste bags

• Label all plastic contaminated waste bags with type and estimated quantity of spilt

material, place in the designated contaminated soils / solid waste bags, and

removed off site to a licensed facility after the survey is complete

• Restore the terrain to its original condition (using earth-moving equipment to back

blade the site, or shovels to fill in any holes as required)

Mobile transport spill kits, shovels and large bags will be located on the light vehicle and

will have the capability to clean up a credible maximum spill (180 litres). The spill kits will

be effective on fuels, oils, and hydraulic fluids and will meet approved standards pertaining

to the handling, storage, clean up and disposal of Dangerous Goods and Hazardous

Substances.

The mobile spill kit will contain the following (or similar):

• Spill Kit Bag

• KleenSweep bag (powered absorbents)

• Absorbent Pad

• Oil Sock

• Nitrile Gloves (disposable)

• Waste Disposable Bags

• Cable Tie

• Instruction Card

During the geochemical activities’ audits and inspections of the mobile spill kits will be

undertaken by the operator in order to ensure that kits are complete, located on the vehicle

and ready for use in case of a spill. Audits and inspections of spill kits will also be

undertaken by the operator following any spill incidents.

The incidents register will be updated to record all spill events and the clean-up method

used and receipts of waste acceptance from licenced facilities will be recorded to show

evidence of clean up. Inspection reports will be kept and maintained in Rey’s Inspection

and Audit Register (RLS_CMS_REG_008).

Gulliver’s management will ensure any hydrocarbon or chemical spills are reported to the

appropriate contacts within the DMIRS, in accordance with Section 9.3.




As per Gulliver’s Stakeholder Engagement Management Plan

(RLS_CMS_MPL_001_Rev_1), Toxfree in Derby is the identified ‘third party’ to assist in

emergency spill responses. Two to three weeks prior to undertaking the activities, Toxfree

will be contacted to confirm availability to provide emergency response and spill clean-up

as well as contaminated soil testings and disposal should it be required. Toxfree Derby

contact details are as follows:

Regional Manager, Industrial Services

Lot 909 Millard Way, Derby WA 6728

[email protected]

08 9161 6400

mailto:[email protected]




Reporting (Regulations 16, 28, 29 and

30)

9.1 Prestart and Cessation Notifications

Gulliver will inform DMIRS of the start date prior to commencing any surveying activities

(ie. Date of first mobilisation to site) and provide notification of the completion date within

one week from cessation of surveying activities (ie. Date of Demobilisation from site).

It is proposed the Geochemical Survey will be undertaken in the fourth quarter of 2019.

9.2 Activity Reporting (Annual Environmental

Reports)

Legislation under the PGER(E)R, Onshore Schedule and the PGER Act, requires

operators to report various environmental aspects of their operations to DMIRS, and all

environmental reports submitted electronically to:

[email protected]

The environmental activity reporting includes;

• Activity Reporting (Annual)

• Incident Reporting (As required)

• Emissions and discharges reporting (Quarterly).

Environmental reporting requirement on compliance, emission/discharges and incidents

are listed below. The activity/environmental report will be submitted annually within three

months of the date that this EP is accepted.

9.2.1 Staged Reporting

There is no proposed disturbance or major activities associated with the proposed

Geochemical Survey.

9.3 Incident Reporting

9.3.1 Reportable Incidents

The Regulations define a reportable incident as an incident that is classified as reportable

under the EP for the activity and has caused or has the potential to cause an adverse

environmental impact; and an impact that is categorised as moderate or more serious than

moderate.

Table 13 summarises the reporting requirements for Environmental incidents that Gulliver

will abide by. These reportable incidents are derived from the risk assessment undertaken

in Section 4. where inherent risks had a rating of Moderate or above.





Table 13: Summary of Reporting Requirements

Reportable Incident Additional Reporting Requirements Timeframe

Fauna/vehicle interaction

Within 2

hours - initial

report.

Within 3

days – full

report.

Introduction of spread of

weeds

Fire ignition source from

vehicles or personnel

Recordable Incident

Refer Section 9.3.2.

Even if no incidents occurred during the

month, the DMIRS Recordable Incident

Monthly Report will be submitted to

[email protected]

Within 15

days of end

of calendar

month in

which the

incident

occurred

(monthly).

Reportable incidents will be reported to the DMIRS via the 24-hour duty phone 0419 960

621, and under Regulation 29, a written report is to be submitted to DMIRS

([email protected]) as soon as practical, and no later than three

days after the initial incident.

The following information will be provided with the incident report:

• Facility name, title, site name or location where the incident occurred

• Name and business address of the company that manages the activity

• Time and date of the incident

• Names and contact details of any witnesses

• Name, position and telephone number of person(s) submitting the details

• Incident details and description

• Activity being undertaken at the time of the incident

• Estimated quantity, composition and known toxicity of any fluids that escaped

• Duration of escape (if relevant)

• Details of any environmental impacts

• Immediate response actions taken to prevent further environmental impact






• Arrangements for internal root cause analysis investigation (note that regulatory

investigation may be required and will be evaluated once the report is received)

• Corrective actions proposed to prevent recurrence of further or similar incidents.

Possible reportable incidents as a result of the proposed activity (geochemical survey)

includes the following:

• Hydrocarbon spills (diesel from light vehicle).

• According to the (then) DMP (Resources Safety) Reporting dangerous goods

incidents – Guideline 6th Edition, a loss not contained on site for a C1 combustible

liquids (diesel) of 100 litres is required to be reported.

The Site Supervisor must maintain the incident reporting system to minimise

environmental harm and to encourage the prevention of more serious incidents. All

personnel are encouraged to report all events as a means of alerting environmental risks

and maintaining a program of continual improvement.

9.3.2 Recordable Incidents

Recordable incidents are those which breach an environmental performance objective or

environmental performance standard defined in the Environment Plan and is not a

reportable incident and must be reported to DMIRS.

Recordable incidents include, but are not limited to:

• Introduction or spread of listed weed species

• Excessive erosion

• Fauna deaths

• Noise disturbances to neighbouring properties

• Disturbance to existing native vegetation

• Unacceptable reinstatement following site inspection activities.

Under Regulation 30 of the PGER(E)R, a copy of DMIRS’ Recordable Environmental

Incident Report Form listing all recordable incidents each month will be completed by

Gulliver and submitted to DMIRS ([email protected]) as soon as

practicable, and within 15 days after the end of the month to which it relates.

The report will include details of any recordable incidents, including:

• All material facts

• Actions taken to avoid or mitigate any adverse environmental impacts occurring from

the incident

• Any action taken, or proposed to be taken, to prevent similar recordable incidents.





9.4 Emissions and Discharges Reports

Regulation 34 of the PGER(E)R requires the monitoring and reporting of all emissions and

discharges to any land, air, or surface water/groundwater environment. Gulliver will

provide a written report detailing all emissions and discharges that occur during the

surveying activities. This report must be submitted to DMIRS within 15 days from when

the surveying is completed.

The report will address any emissions or discharges during the survey, including but not

limited to:

• Vehicle and equipment emissions

• Details of any emission resulting from environmental incidents such as spills

• Waste; including general, hazardous and recyclable.

The only proposed activity in this EP is Geochemical Survey which involves one light vehicle

driving over a period of three days. Therefore, combustion of fuel to power the vehicle is

the only anticipated reportable item.

Gulliver does not anticipate emissions resulting from the survey activities will met the

National Greenhouse and Energy Reporting (NGER) Act requirements. Fuel consumption

will be recorded as atmospheric emission estimates (CO2e-) from fuel usage (based on

the NGER threshold estimator) (Clean Energy Regulator 2019).

Any unplanned emissions (e.g. hydrocarbon spills as per Table 13 above) will be reported

to DMIRS as an incident report.




Stakeholder Engagement (Regulation 17)

A formal Stakeholder Engagement Register (RLS_CMS_REG_007) and Stakeholder

Engagement Plan (RLS_CMS_REG_001) have been prepared to undertake and maintain

a structured format for ongoing consultation associated with the geochemical surveying

tasks.

10.1 Principles of Stakeholder Engagement

Gulliver will provide all necessary stakeholders with a fair timeframe to review, consider

and respond to the project information. Throughout this strategy, Gulliver will consider and

apply the Principles of Stakeholder Engagement from the Ministerial Council on mineral

and Petroleum Resources (MCMPR) Principles for Engagement with Communities and

Stakeholders (2005). These principles include; Communication, Transparency,

Collaboration, Inclusiveness and Integrity.

10.2 Targeted Community and Stakeholder

Engagement Strategy

Gulliver recognises the low impact level of the geochemical survey and will tailor the

stakeholder engagement strategy to suit. Key potential stakeholders have been identified

in the table below (Table 14). Gulliver will modify the strategy should any change arise in

the activities and or the needs of the interested stakeholders.

10.3 Potential Stakeholders

In accordance with Regulation 17 of PGER(E)R, Gulliver Resources consider the

stakeholders outlined in Table 14 to be relevant to the activities within this EP.

Table 14: Potential Stakeholders

Stakeholders Relevance Justification Relevant to

this Plan

Shire of Derby/West

Kimberley

As the activity is located within this shire, they

are considered a relevant stakeholder.

Yes

Jumbuck Pastoral Office

(Holder of Meda Station

pastoral Lease)

As the petroleum titles overlap the Meda

Station, Gulliver activities have the potential to

interfere with works on their land and are

therefore considered a relevant stakeholder.

Yes

Native Title Claimant

Group

Due to the Native Title claim on the area,

liaison with Aboriginal Community Leaders

would be required.

Yes

Department of Mines,

Industry Regulation and

Safety

Since the EP is required to be submitted and

approved by DMIRS for the proposed activities,

they are considered a relevant stakeholder.

Yes




Stakeholders Relevance Justification Relevant to

this Plan

Police and Emergency

Services

Generally, the activities associated with the

geochemical survey are reasonably remote and

therefore local authorities will be made aware

of locations in case of emergency. As per Rey’s

internal stakeholder engagement plan, the WA

police and local emergency services will be

contacted 2-6 weeks prior to the planned

activities. They will be notified of the areas and

duration of activities and the internal safety

management systems.

Yes

Padilpa-1 well Padilpa-1 well is located 6 km north west of the

Geochemical Survey activity area. It is unlikely

that Rey’s activities will interfere with Padilpa-1

area. Records of the well state it is plugged

and abandoned and therefore it is unlikely that

there will be activity at that well.

No

10.4 Initial Project/Activity Engagement (During

EP Development)

Gulliver has undertaken stakeholder engagement with relevant stakeholders during the

development of the EP. Table 15 below outlines this engagement.

Table 15: Stakeholder Engagement Table

Stakeholders Name and Date of

Consultation Consultation

Activity

Related Issue

Objection /

Claim?

Shire of

Derby/West

Kimberley

Email and phone

calls, June 2019

Notification of

proposed

activities

NA

The Shire has

reviewed the

information

provided and

does not have

any concern

or formal

advice to offer

regarding the

proposed

activities.

Meda Station

Emails and phone

calls, June and July

2019

Notification of

proposed

activities

NA

Response yet

to be

received.

Agreement to

undertake the




10.5 Ongoing Engagement (Post Approval)

Due to the nature and low impact scale of the surveying activities, the level of ongoing

consultation is planned to be minimal. Gulliver commits to providing updates to

stakeholders where planned activities differ from those outlined in this EP including

changes to proposal and notification of significant aspects of the surveying.

This also provides a platform for ongoing stakeholder communication with Gulliver

regarding concerns, feedback and queries, and Gulliver commits to keeping DMP informed

with any significant concerns raised.

10.6 Recording Stakeholder Engagement

All consultation and engagement undertaken for the proposed Geochemical Survey

activities under this EP will be recorded in the Stakeholder Engagement Register

(RLS_CMS_REG_007).

The register will include the following details of each engagement:

• Date of consultation and timeframe provided for response

• Person, department, or organisation consulted (position, branch, company etc.)

• Method of consultation (i.e. meeting [minutes], letter, email)

• A summary of the information provided

• Details of all questions, comments, or concerns raised by the stakeholder

• Any conditions imposed (where appropriate)

• Evidence demonstrating that all questions, comments, issues or concerns raised have

been adequately addressed to the satisfaction of the party who raised the question,

comment, issue or concern.

survey at

Meda Station

will be

obtained prior

to

commencing

any activities.

Native Title

Claimant

Groups (R1 -

Mawadjala

Gadjidgar,

EP104 -

Bindunbur)

Ongoing emails and

meetings.

Two native title

agreements NA

Agreements

still being

drafted.




References Australian Bureau of Statistics. (2016). Census QuickStats. Retrieved from

http://www.abs.gov.au/websitedbs/D3310114.nsf/Home/2016 QuickStats

Bureau of Meteorology. (2019). Monthly climate data statistics. Retrieved from

www.bom.gov.au/climate/data

Department of Biodiversity Conservation and Attractions. (2019). NatureMap. Retrieved

from https://naturemap.dpaw.wa.gov.au/

Department of Planning Lands and Heritage. (2018). Aboriginal Heritage Inquiry System.

Retrieved from https://maps.daa.wa.gov.au/ahis/

Department of Primary Industries and Regional Development. (2018). Soil landscape

Mapping - Systems - GIS Dataset.

Department of the Environment and Energy. (2016). Interim Biogeographic

Regionalisation for Australia, Version 7. Retrieved from

www.environment.gov.au/land/nrs/science/ibra/

Department of the Environment and Energy. (2019). Protected Matters Search Tool.

Retrieved from http://www.environment.gov.au/epbc/pmst/

Department of Water and Environmental Regulation. (2019). Public Drinking Water

Source Areas - GIS Dataset.

Department of Mines and Petroleum (2011). Reporting dangerous goods incidents —

guideline (6th edition): Resources Safety, Department of Mines and Petroleum,

Western Australia, 8 pp.

Graham, G. (2001). A Biodiversity Audit of Western Australia’s 53 Biogeographical

Subregions in 2002.

State Heritage Office. (2019). Heritage Council WA - State Register.




FIGURES


&<?

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EP 104 R6


Stokes Bay 1

±



Pre-European VegetationDAMPIERLAND 127DAMPIERLAND 43DAMPIERLAND 750FITZROY SANDPLAINS 127FITZROY SANDPLAINS 43FITZROY SANDPLAINS 755

!( !(

!(

!(

!(

!(DERBY

OOBAGOOMA

KING SOUND

LOCALITY MAP

DATEPROJECT ID

HT MR


0




Figure 2 Vegetations Systems

SL

0 5,000 10,000Meters

4/06/20193238




@ A41:300,000


&<?

&<?

EP 104 R6


Stokes Bay 1

±



Soil and Land SystemsCoastal country, bare mud flats andsaline soils with halophytic vegetation.Coastal plains, extensive bare mudflats, associated sandy margins andminor dunes, saline sands and muds,supporting paperbark thickets,samphire shrublands and fringingmangrove forests.Low sandy plateaux and lower slopessupporting pindan woodlands withacacias and eucalypts and curlyspinifex-ribbon grass, and valley plainssupporting mixed woodlands withribbon grass.Red sandplains supporting pindanvegetation with dense acacia shrubs,scattered bloodwood and grey boxtrees and curly spinifex and ribbongrass.Sandplains and linear dunessupporting pindan woodlands withacacias and bloodwoods and curlyspinifex- ribbon grass, and broad low-lying swales supporting bloodwood-grey box woodlands with curly spinifex-ribbon grass.

!(

!(

!(DERBY

OOBAGOOMA

KING SOUND

LOCALITY MAP

DATEPROJECT ID

HT MR


0




Figure 3 Soil and Landsystems

SL

0 5,000 10,000Meters

4/06/20193238




@ A41:300,000


&<?

&<?

EP 104 R6


Stokes Bay 1

±



HydrographyWatercourse - majorWatercourse - minorNatural PoolSwampMarine Construction -wharf/jettyReef Area

!( !(

!(

!(

!(

!(DERBY

OOBAGOOMA

KING SOUND

LOCALITY MAP

DATEPROJECT ID

HT MR


0




Figure 4 Hydrology

SL

0 5,000 10,000Meters

4/06/20193238




@ A41:300,000


&<?

&<?

EP 104 R6

R 1 R2PointTorment 1

Stokes Bay 1

±


&<? Petroleum WellsGeochemical Survey LinesEnvironmentally SensitiveAreasWild River: Priority 1

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

DERBY

YEEDA

LOMBADINA

OOBAGOOMA

BEAGLE BAY KING SOUND

PENDER BAY

SUNDAY STRAIT

KIMBERLY DOWNS

LOCALITY MAP

DATEPROJECT ID

HT MR


0




Figure 5 Conservation Features

SL

0 11,000 22,000Meters

4/06/20193238




@ A41:700,000


&<?

&<?

EP 104 R6

R 1 R2

Place ID: 14617(MOWANJUM MISSION)

PlaceID: 17096(TEA03)

PlaceID: 17097(TEA01)Place

ID: 17099(TEA04)

PointTorment 1

Stokes Bay 1

PlaceID: 12392

(MARADJA)

Place ID: 12391(BINDJARNURRU)

Place ID: 12393(KUNUMUDJ)

Place ID: 13240(DERBY

LEPROSARIUM)

±



Aboriginal HeritageRegistered SitesLodged Sites

!( !(

!(

!(

!(

!(DERBY

OOBAGOOMA

KING SOUND

LOCALITY MAP

DATEPROJECT ID

HT MR


0




Figure 6 Heritage

SL

0 5,000 10,000Meters

4/06/20193238




@ A41:300,000

Site ID Name Site Type 17,099 TEA04 Lodged

17,097 TEA01 Lodged

17,096 TEA03 Lodged

17,095 TEA02 Lodged

17,443 Meda Dune Registered Site

13,240 Derby Leprosarium

Registered Site

Artefacts/Scatter. Grinding patches/Grooves

Located approximately 1.5km SW of West-Kora 1

Ceremonial, Modified Tree, Mythological

Located approximately 1.5km SW of West-Kora 1

Midden/Scatter, Shell Within 5km of survey tracks in R1


Shell Within 5km of survey tracks in R1


Type Location




APPENDIX A Environmental Policy

CORPORATE HEALTH AND SAFETY POLICY Gulliver Productions Pty Ltd (“Gulliver”), a wholly owned subsidiary of Rey Resources Ltd, places the highest priority on conducting its activities in a healthy and safe manner. Our aim is to meet or exceed the standard expected of the industry by the community and government for conducting a healthy and incident-free operation. To accomplish this Gulliver will:

• Comply with and actively participate in the formulation of all applicable to health and safety laws, regulations, licences and industry standards;

• Provide ongoing health and safety management training to our employees;

• Maintain a health and safety system as an integral part of our business operations to ensure that the

risk of injury or damage to the health of our employees, contractors and visitors is as low as reasonably practicable;

• Maintain a system of continuous improvement in our management of health and safety;

• Endorse a positive health and safety culture in our employees and contractors;

• Set measurable targets in the management of health and safety;

• Utilise contractors who meet or exceed Gulliver’s health and safety standards; and

• Respond quickly and effectively to any emergency, which impacts the health and safety of our

employees, contractors or visitors.

All Managers and Supervisors are responsible for the development and implementation of safety management processes designed to achieve the objectives of this Policy and all personnel shall, where practicable, participate in the process. Contractors will adopt this overarching SMS framework when performing agreed work under Gulliver’s management. Gulliver will ensure the effectiveness of this Policy. All employees are required to comply with the policies, procedures and systems of work developed in accordance with this Policy. This policy applies to all activities where Gulliver has a prevailing influence.

Wei Jin Managing Director May 2019




APPENDIX B Master Document Register

Role Name

RLS_IMSM Corporate (CMS) Integrated Management System Manual A

RLS_SMSM Safety (SMS) Health and Safety Management System Manual 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

GP_SMSM Safety (SMS) Safety Management System A

RLS_CMS_POL_001 Corporate (CMS) Corporate Policy Statement A

RLS_CMS_POL_002 Safety (SMS) Safety Policy Statement A

RLS_EMS_POL_001 Environment (EMS) Environment Policy Statement A

RLS_CMS_PRO_001 Corporate (CMS) Document and Record Control Procedure 2 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_PRO_002 Corporate (CMS) Monitoring and Measuring of Performance Procedure 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_PRO_003 Corporate (CMS) Communication and Consultation Procedure 2 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_PRO_004 Corporate (CMS) Internal Audit and Inspection Procedure 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_PRO_005 Corporate (CMS) Hazard and Risk Management Procedure 2 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_PRO_006 Corporate (CMS) Emergency Response Procedure 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_PRO_007 Corporate (CMS) Event and Feedback Reporting and Investigation Procedure 2 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_PRO_008 Corporate (CMS) Contractor Evaluation Procedure 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_PRO_009 Corporate (CMS) Induction and Training Procedure 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_PRO_010 Corporate (CMS) Review of Legislation and Compliance Procedure 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_PRO_011 Corporate (CMS) Spill Response Procedure 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_PRO_012 Corporate (CMS) Job Safety and Environment Analysis (JSEA) Procedure 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_SMS_PRO_001 Safety (SMS) Fitness for Work Procedure 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_SMS_PRO_002 Safety (SMS) Return to Work Procedure 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_SMS_PRO_003 Safety (SMS) Road Travel Management Procedure 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_SMS_PRO_004 Safety (SMS) Isolation and Tag out Procedure 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_EMS_PRO_001 Environment (EMS) Hygiene and Weed Inspection Procedure 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_EMS_PRO_002 Environment (EMS) Vegetation Line Clearing Procedure 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_EMS_PRO_004 Environment (EMS) Rehabilitation Procedure 1 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_MPL_001 Corporate (CMS) Stakeholder Engagement Plan 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_SMS_MPL_001 Safety (SMS) Health and Safety Management Plan 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_EMS_MPL_001 Environment (EMS) Environmental and Heritage Management Plan 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_FRM_001 Corporate (CMS) Hazard and Risk Report Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_FRM_002 Corporate (CMS) Event and Feedback Report Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_FRM_003 Corporate (CMS) Internal Audit Report Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_FRM_004 Corporate (CMS) Internal Audit and Inspection Observation Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_FRM_005 Corporate (CMS) Contractor Evaluation Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_FRM_006 Corporate (CMS) Detailed Investigation Report Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_FRM_007 Corporate (CMS) Worksite Inspection Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_FRM_008 Corporate (CMS) Job Safety and Environment Analysis (JSEA) Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_SMS_FRM_001 Safety (SMS) Motor Vehicle Inspection Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_SMS_FRM_002 Safety (SMS) Journey Management Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_SMS_FRM_003 Safety (SMS) Safety Alert Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_SMS_FRM_004 Safety (SMS) Take 5 Form 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_SMS_FRM_005 Safety (SMS) Return to Work Plan 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

Master Document Register

Review date

Procedures

Forms and Checklists


Document ownerApprover

Effective

dateRevisionTitleDocument # System

Management Plans

Uncontrolled if PrintedIssued 22/09/2016

Reviewed 27/5/2019

Role Name

Master Document Register

Review date


Document ownerApprover

Effective

dateRevisionTitleDocument # System

Uncontrolled if PrintedIssued 22/09/2016

Reviewed 27/5/2019

RLS_CMS_IND_001 Corporate (CMS) EP 487 HSE Induction A in prep Project Manager Stanley Fu Stanley Fu

RLS_CMS_QUE_001 Corporate (CMS) EP 487 HSE Induction Questionnaire A in prep Project Manager Stanley Fu Stanley Fu

RLS_CMS_REG_001 Corporate (CMS) Master Document Register 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_REG_002 Corporate (CMS) Event and Feedback Register 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_REG_003 Corporate (CMS) Approved Supplier Register 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_REG_004 Corporate (CMS) Hazard and Risk Register 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_REG_005 Corporate (CMS) SDS Register 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_REG_006 Corporate (CMS) Induction and Training Register 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_REG_007 Corporate (CMS) Stakeholder Engagement Register A 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_REG_008 Corporate (CMS) Audit and Inspection Register 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_REG_009 Corporate (CMS) Legislation and Compliance Register 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

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RLS_SMS_REG_001 Safety (SMS) Isolation and Tag Out Register 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_EMS_REG_001 Environment (EMS) Environmental Impacts and Aspects Register 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_EMS_REG_002 Environment (EMS) Vegetation Clearing Register 0 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

RLS_CMS_TMP_001 Corporate (CMS) Document Template B 15/05/2019 15/05/2021 Project Manager Stanley Fu Stanley Fu

Legal/Standards/Guidelines/Licencing etc.

Lists, Indexes and Registers

Templates

Training and Induction Packages




APPENDIX C Spill Response Procedure

SPILL RESPONSE PROCEDURE

RLS_CMS_PRO_011_Rev_1

Page 1 of 5

SP ILL RESP ON S E P ROCEDURE -

R LS _C MS_P RO _0 11 _REV _ 1 1 . 0 P U R P O S E

This procedure outlines the commitments of RLS Lennard Shelf Pty Ltd (RLS) and the regulatory and

environmental requirements applicable in the event of a hydrocarbon, chemical or oil spill incident. The

purpose of this procedure is ensure that all action is taken to minimise the impact of hydrocarbons and

chemicals on the environment and personnel safety by ensuring hydrocarbon chemicals are properly

contained, treated, transported and disposed of.

2 . 0 S C O P E

This procedure applies to all personnel and contractors conducting business on RLS sites.

3 . 0 R E S P O N S I B I L I T I E S

Position Responsibilities

Management Ensure personnel and contractors are aware of the project/site-specific Spill Clean

Up Procedure and Oil Spill Contingency Plans.

Ensure all spills and associated incidents are reported to the relevant authorities.

Supervisors Ensure that personnel operate within the appropriate legislative requirements, and

the project/site-specific Spill Clean Up Procedure and Oil Spill Contingency Plans

(found in the Environment Plan).

Oversee and audit spill responses, in the interests of continual improvement.

Personnel Ensure all spills, incidents and near misses are responded to appropriately and

reported to RLS Management.



Page 2 of 5

4 . 0 S P I L L D E F I N I T I O N S

Level Definition

Minor spill Spill contaminates the surface of the ground not in excess of 0.50 m2 in area and 0.50 cm

in depth. The spill can be effectively contained and cleaned up by a single department or

team using the containment kit, plastic packets and / or a pressure hose.

Moderate spill A spill that would require the assistance of other departments or teams to contain and

clean up (i.e. use of additional clean up kits, personnel or equipment).

Major spill A spill that cannot effectively be contained or cleaned up with the resources available on-

site. External contractor or emergency services help is required.

5 . 0 P R O C E D U R E

5.1 GENERAL REQUIREMENTS

Immediate action by all personnel in the event of a spill is containment to the best of their ability given

equipment available to them, and as long as there is no risk to safety. Containment must be attempted prior

to any other actions, including notification.

The first point of contact for all staff reporting a spill is the Site Supervisor. Depending on the severity of the

incident, RLS management may also be contacted.

The Site Supervisor (or most senior person on-site at the time of the spill) assesses the spill to determine

severity and implements the appropriate response according the clean-up response (i.e. ‘minor to moderate

spill pathway’ clean-up process or ‘major spill pathway’ clean-up process).

When containing and cleaning up spills, personnel are to ensure all safety precautions are in place i.e. PPE,

chemical PVC gloves, and ensuring fire extinguishers are readily available, no one is smoking and all vehicle

engines are switched off.

All efforts must be aimed at rapidly deploying the containment kit and/or sand so as to reduce the spillage area

as much as possible, and always work up hill and up wind from the spill.

Following any spill, every effort should be made to restore the affected area to its original condition, ensuring

all contaminants are removed and disposed of correctly.



Page 3 of 5

5.2 MINOR TO MODERATE SPILLS

In the event of a minor to moderate spill:

• Personnel must immediately obtain the emergency response clean‐up/containment kit

• Contain spread by constructing a bund around the spill area (i.e. with socks or sand)

• For ground spills, use spill material to absorb maximum amount of fluid possible, then transfer fluid-

soaked materials into plastic contaminated waste bags

• Use a shovel to dig up and remove any contaminated sand, gravel or rocks and also transfer into plastic

contaminated waste bags

• Label all plastic contaminated waste bags with type and estimated quantity of spilt material, then bring

back to camp and place in the designated contaminated soils, solid waste bins

• Restore the terrain to its original condition (using earth-moving equipment to back blade the site, or

shovels to fill in any holes as required).

5.3 MAJOR SPILLS

In the event of a major spill:

• Cordon off the area and make it safe

• If on a major road, immediately call the local police and/or Emergency Services so that they may

control the scene and coordinate the clean‐up, and also advise of the most appropriate action prior to

their arrival

• If an associated fire hazard, evacuate the area immediately to a minimum distance of 500 m and await

the arrival of the Emergency Services

• Until the police or Emergency Services arrive, the Site Supervisor and/or most senior staff member at

the site of the spill will be in charge of the scene, assigning personnel/resources to area as necessary

• Personnel should be safely positioned to warn, slow down, and if necessary redirect traffic around the

hazard pending the arrival of Emergency Services or Police

• Vehicles are to be parked on the side of the road, uphill and up‐wind, well away from the spill, with

beacon lights and emergency hazard lights on

• A licensed third party will undertake the spill clean‐up, with the assistance of site crew, as required.



Page 4 of 5

5.4 REPORTING AND AUDITING

All spills are to be reported to the Site Supervisor and in accordance with Event and Feedback Reporting and

Investigation Procedure (RLS_CMS_PR_007).

RLS management will ensure any hydrocarbon or chemical spills are reported to the appropriate contacts

within the Department of Mines, Industry Regulation and Safety (DMIRS), in accordance with the table below.

DMIRS Reporting Contacts (Incident Reporting)

DMIRS

Environment

24 hr Duty Phone

Reportable (environmental) incidents

reported ASAP, no more than 2 hours after

the incident

0419 960 621

[email protected]

DMIRS Safety

24 hr Officers

All accidents and dangerous occurrences in

relation to petroleum, pipeline and

geothermal operations requiring

immediate notification

Office hours (8.30 am to 4.30 pm)

9358 8002

After hours, the following numbers in listed

order:

0439 964 143 (Contact 1st)

0428 882 604 (Contact 2nd)

And written email notification to

[email protected]

During site projects/operations, weekly audits and inspections of all spill kits will be undertaken by the Site

Supervisor or delegate in order to ensure that kits are complete, in the correct locations and ready for use in

case of a spill. Audits and inspections of spill kits will also be undertaken by the Site Supervisor or delegate

following any spill incidents. All inspection reports will be kept and maintained in RLS’s Inspection and Audit

Register (RLS_CMS_REG_008).

6 . 0 R E L A T E D D O C U M E N T S

• Event and Feedback Reporting and Investigation Procedure (RLS_CMS_PR_007)

• Inspection and Audit Register (RLS_CMS_REG_008).



Page 5 of 5

7 . 0 R E V I E W

This procedure shall be reviewed every two years or as part of the management review as a required.

8 . 0 R E V I S I O N D E T A I L S

Revision

Number Revised by

Reviewed/

Approved by Issued Date Change Notes

A W. Bauer-Simpson B. van der pols 03/08/2016 Initial draft

B W. Bauer-Simpson S. Fu 16/08/2016 Reviewed by RLS

0 W. Bauer-Simpson S. Fu 25/08/2016 Approved for implementation

1 H Taylor Stanley Fu 22/5/19 Reviewed. Updated department

names and contact details in section

5.4

Documents

EP104 & R1