INDRA...INDRA 28-SEP-2018 UNCONTROLLED WHEN PRINTED DOC-EIMP- Code A.\rAccepted. \rA. Black 28/09/18 GREENCAP PTY LTD 11 Winnellie Central, 14 Winnellie Road, Winnellie, NT 0820, P

$Page 1: INDRA...INDRA 28-SEP-2018 UNCONTROLLED WHEN PRINTED DOC-EIMP- Code A.\rAccepted. \rA. Black 28/09/18 GREENCAP PTY LTD 11 Winnellie Central, 14 Winnellie Road, Winnellie, NT 0820, P$
SHEET 1 OF 210

Subcontractor's name Greencap Pty Ltd

Subcontract No. 0 6037- P- 3365-SC119

Subcontract Package Name: ENVIRONMENTAL IMPACT MONITORING PROGRAM

DOCUMENT TITLE: WASTE DISCHARGE LICENCE 211 ANNUAL RETURN 2018 – BLADIN

POINT - ENVIRONMENTAL IMPACT MONITORING PROGRAM

Subcontractor's Doc. No.: AEC320

ICHTHYS ONSHORE LNG FACILITIES

Darwin, Australia

Subcontractor

ISSUE PURPOSE □FA □FR □FI XFC □AB □CA

CTR RESULT CODE

□A □B □ N □F

NEXT STATUS : □ FA □FR □FI □FC □AB □NA

Subcontractor RESUB / NEXTSUB DATE :

Approval or review hereunder shall not be construed to relieve Vendor / Subcontractor of his responsibilities and liability under the Contract.

CTR ORGANIZATION DEPT. NAME SIGNATURE

PJ DEPT.

RESPONSIBLE DEPT.

RELATED DEPT.

CTR REVIEW DATE :

JOB. NO. 0-6037-2 REVIEW CLASS 3

CPY DOC.no.

SYSTEM no. - CLASS/DISC. - TYPE - SERIAL no. REV

L 290 - AH - REP - 10898

0 CTR

DOC.no.

Subcontract No. - SERIAL no..

V - 3365 - SC119 - 8320

INDRA28-SEP-2018

UNCONTROLLED WHEN PRINTED

black.anthony

Text Box

DOC-EIMP- Code A. Accepted. A. Black 28/09/18

black.anthony

Oval

black.anthony

Oval

GREENCAP PTY LTD11 Winnellie Central, 14 Winnellie Road, Winnellie, NT 0820, P O BOX 39546, Winnellie NT 0820

Ph: 08 7906 1300 Fax: 08 8984 3105 Email: [email protected] Web: www.greencap.com.au

Prepared by:

Ichthys On-Shore LNG Facilities

Bladin Point

Waste Discharge Licence 211 Annual Return 2018

Prepared for:JKC Australia LNG Pty Ltd

Date: 26 September 2018

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Waste Discharge Licence 211 Annual Return 2018 – Bladin Point –

Environmental Impact Monitoring Program

Contractor Doc. No: V-3365-SC119-8320

Company Doc. No: L290-AH-REP-10898

AEC Doc No.: AEC320

GREENCAP DOCUMENT CONTROL

Report Title & Job Ref: Waste Discharge Licence 211

Annual Return 2018 – Bladin Point – Environmental

Impact Monitoring Program

Filename: V-3365-SC119-8320_0_0001

Written: Checked: Approved:

Kanchana Warnakulasooriya

Co-ordinating Author

Chris Gamble

Project Coordinator

Brent Ridgard

Project Director

Rev No. Status Date Author Checker Reviewer

A Draft 7/09/2018 KW CG BR

0 Final 26/09/2018 KW CG BR

Rev No Copies Recipient

A 1 x Electronic Copy JKC Australia Pty Ltd

0 1 x Electronic Copy JKC Australia Pty Ltd

INDRA28-SEP-2018


Waste Discharge Licence WDL 211 Annual Return 2018 i

Contractor Doc. No: V-3365-SC119-8320, Company Doc. No: L290-AH-REP-10898 (Ref: - AEC320)

TABLE OF CONTENTS

LIST OF APPENDICES ......................................................................................................... i

1. WASTE DISCHARGE LICENCE 211-4 ......................................................................... 1

2. GENERAL ..................................................................................................................... 2

3. EARLY SURRENDER OF LICENCE ........................................................................... 10

4. OPERATIONAL ........................................................................................................... 11

5. DISCHARGES ............................................................................................................. 15

6. MONITORING ............................................................................................................. 22

7. RECORDING AND REPORTING ................................................................................ 34

8. REFERENCES ............................................................................................................ 39

LIST OF APPENDICES

Appendix A NT EPA Information Requests

Appendix B Ichthys Onshore LNG Facilities Community Relations Plan

Appendix C Community Bulletin (Issue #242) and Project Bulletin (August 2018)

Appendix D Ichthys Onshore LNG Facilities Emergency Response Plan

Appendix E Spent Water Re-use Permit Examples

Appendix F Diffuser Design and Outfall Piping Plan

Appendix G Discharge Permits

Appendix H Sample Location Signage

Appendix I WDL 211-4 Non-Compliance Notifications

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Waste Discharge Licence 211 Annual Return 2018 1 2


1. WASTE DISCHARGE LICENCE 211-4

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Waste Discharge Licence 211 Annual Return 2018 2


2. GENERAL

1. Condition The Licensee must notify the administering agency within 24 hours if there is a change to the licensee or emergency

contact details as provided on page one of this licence

How Verification from Kresho Zic (JKC Project Environment Manager) and Shoanne Labowitch (JKC Government Approvals

Advisor) that the Licensee and emergency contact details are correct and current.

Evidence Desktop review completed on 29/08/2018.

When (Date) Compliant.

Status Compliant

2. Condition The Licensee must notify the administering agency within 14 days after ceasing to conduct the activity to which this

licence relates.

How Desktop review.

Evidence The Licenced activity: Discharge of spent waters from hydrotesting, testing and commissioning activities relating to

construction, commissioning and pre-start of the Ichthys Onshore LNG Facility at Bladin Point remains active and notification

was not required during the annual reporting period.

When (Date) Desktop review completed on 29/08/2018.

Status Compliant.

3. Condition The Licensee must notify the administering agency prior to making any operational change that will cause, or is likely

to cause, an increase in the potential for environmental harm.

How Desk top review.

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Evidence JKC Lead Environmental Advisor has confirmed that no operational changes with regards to the discharge of spent waters

occurred that would cause, or likely to cause, an increase in the potential for environmental harm, environmental nuisance,

material environmental harm or serious environmental harm. Discharge operations remained as per the details provided within

the Hydrotest Environmental Management Plan (HEMP) (L290-AH-PLN-0023) and the Hydrotest Discharge: Environmental

Monitoring Plan – Supporting Documentation (EMP) (L290-AH-PLN-10231) submitted to NT EPA with the original and

amended Licence applications.


Status Compliant.

4. Condition The licensee must cause a copy of this licence to be available for inspection by any person, in hard copy form, at the

premises.

How Site inspection.

Evidence A hard copy of the licence is maintained in the Project Environment Manager’s office at the Bladin Point Ichthys LNG, 144

Wickham Point Road, Wickham Point NT. A site inspection has been conducted to verify, with hard copy sighted.

When (Date) A site inspection was conducted and a hard copy of WDL 211-4 was sighted on 1/09/2018.

Status Compliant.

5.

Condition The licensee must provide to the administering agency, within 10 business days of a request, a copy of any

document, monitoring data or other information in relation to the activity, in the format requested by the

administering agency.

How Consultation.

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Evidence Two information requests were received from the NT EPA during the annual reporting period, as follows:

1. Pertaining to notification of Non-Compliance Reference Number PRL7251. The request for information was received

on 11 July 2018 and stipulated the information be provided by 25 July 2018. The provision of the requested

information occurred on 25 July 2018 in accordance with the NT EPA request.

2. Pertaining to a notification of Non-Compliance associated with an oxides of nitrogen exceedance on 19 July 2018 (no

PLR reference provided). The request for information was received on 22 August 2018. The provision of the requested

information occurred on 27 August 2018 in accordance with this Condition.

The applicable correspondence is given in Appendix A.

When (Date) Consultation completed on 29/08/2018.

Status Compliant.

6. Condition All notices, reports, documents or other correspondence required to be provided as a condition of this licence,

unless otherwise specified as a condition of this licence, must be provided in electronic form by emailing

[email protected].

How Desktop review and consultation.

Evidence A desktop review has confirmed that all notices, documents or other correspondence required to be provided pursuant to WDL

211-4 have been provided in legible and electronic form. This includes all relevant records required under the Administrative

and Recording and Reporting Conditions of WDL 211-4. The only notices, documents and correspondence required to have

been provided to NT EPA under WDL211-4 during the current reporting period were non-compliance notifications issued via

email to [email protected] (refer to Condition 5 for supporting evidence).

The Document Waste Discharge Licence 211 Annual Monitoring Report 2018 – Bladin Point – Environmental Impact

Monitoring Program (Document Reference: L290-AH-REP-10897 (Greencap Pty Ltd, 2018a) and this Annual Return

(Greencap Pty Ltd, 2018b) will be provided in electronic form by 30 September 2018, as specified as a condition of this

Licence.

When (Date) Desktop review and consultation completed on 29/08/2018.

Status Compliant.

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mailto:[email protected]




7. Condition Within 10 business days of any amendment being made to a document listed in Table 1 the licensee must provide the

amended document to the administering agancy, along with:

7.1 a tabulated summary of amendment(s) with document references;

7.2 reasons for the amendment(s); and

7.3 an assessment of environment risk associated with the amendment(s).

Table 1: Environmental document

Document Title

JKC Australia LNG Pty Ltd, Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (L290-AH-PLN-10231).

How Desktop review.

Evidence No amendments were made to the document JKC Australia LNG Pty Ltd, Ichthys Onshore LNG Facilities Hydrotest

Discharge: Environmental Monitoring Plan – Supporting Documentation (L290-AH-PLN-10231).


Status Compliant.

8. Condition The administering agency may require the licensee to revise or amend and resubmit any amended document. Where

the administering agency requires a document to be resubmitted the date for resubmission will be specified and will

become a condition of this licence.

How Consultation.

Evidence No documents were required to be amended during the reporting period.


Status Compliant.

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9. Condition The licensee must, for the duration of this licence, implement, maintain and follow a Consultation and

Communication Plan which includes a strategy for communicating with persons who are likely to have a real interest

in, or be affected by, the activity.

How Desktop review.

Evidence A Community Relations Plan has been developed by JKC. This is an Ichthys Gas Field Development Project-wide plan and

refers to the range of community engagement procedures which are in effect across the Project.

The implementation of the Community Relations Plan is via a range of measures including (but is not limited to):

Website and feedback numbers including a 24 hour / 7 days a week (24/7) 1300 community general enquiry number

and a 24/7 1300 community feedback number;

Community briefing and consult sessions;

Media releases and television advertising;

Fact sheets;

Community newsletters and bulletins;

Specific letter box drops and mail outs when potential construction related impacts may occur; and

Phone surveys.

The Ichthys Onshore LNG Facilities Community Relations Plan (L290-AB-PLN-0150) (JKC Australia LNG Pty Ltd, 2013) is

given in Appendix B.


Status Compliant.

10. Condition The licensee must operate and maintain a community feedback number.

How Desktop review.

Evidence Refer to evidence provided for Condition 9.

The 1300 community general enquiry number and 1300 community feedback number are operational 24/7.


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Status Compliant.

11. Condition The licensee must display the community feedback number:

11.1 where the licensee has a website, in a prominent location on the licensee’s website;

11.2 in the Consultation and Communication Plan; and

14.3 in other publicly available documents relating to the activity.

How Desktop review.

Evidence The licensee does not operate a Project specific website and therefore Condition 11.1 is not applicable. The community

feedback number is however included on the contact page of the Ichthys Project website (http://www.inpex.com.au/contact/).

The Community Relations Plan (Appendix B) refers to the 1300 community hotline.

The 24 hour community hotline number is displayed on publicly available documents such as the Community Bulletin and

Ichthys Project Bulletin. An example of the JKC Community Bulletin (issue #242) and Ichthys Project Bulletin (Issue 33)

displaying the 1300 hotline number has been included in Appendix C.


Status Compliant.

12. Condition The licensee must maintain a Complaint Log for all complaints received by the licensee in relation to the activity.


Evidence The JKC Community Relations department operate a system for complaint monitoring. The complaint monitoring system is an

Ichthys Gas Field Development Project wide system called Database Consultation Manager as part of the implementation of

the Community Relations Plan. All community complaints associated with the Ichthys Gas Field Development Project received

on the 24/7 1300 community general enquiry number and the 24/7 1300 community feedback number are logged.

JKC Lead Environmental Advisor has confirmed that no complaints were received specific to WDL211-4 and its operations.


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http://www.inpex.com.au/contact/



Status Compliant.

13. Condition The licensee must ensure that the Complaint Log includes, for each complaint received by the licensee, the following

information:

13.1 the person to whom the complaint was made;

13.2 the person responsible for managing the complaint;

13.3 the date and time the complaint was reported;

13.4 the date and time of the event(s) that led to the complaint;

13.5 the contact details of the complainant if known, or where no details are provided a note to that effect;

13.6 the nature of the complaint;

13.7 the nature of event(s) giving rise to the complaint;

13.8 prevailing weather conditions at the time (where relevant to the complaint);

13.9 the action taken in relation to the complaint, including any follow-up contact with the complainant; and

13.10 if no action was taken, why no action was taken.

How Consultation.

Evidence Refer to evidence provided for Condition 12.


Status Compliant.

14. Condition The licensee must implement, maintain and follow an Emergency Response Plan that addresses procedures for

responding to emergencies associated with the activity that may cause environmental harm.

How Desktop review.

Evidence An Emergency Response Plan (L290-AH-PLN-0055) has been developed by JKC. This is an Ichthys Onshore LNG Facilities

Project-wide plan and refers to the range of emergency response procedures in effect across the Project.

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The plan does not directly refer to WDL211 (as amended), however, addresses the procedure for responding to marine water

spills and other environmental emergency responses. The Emergency Response Plan has not yet been required to be

implemented in association with WDL211 (as amended) and its activities or operations.

The Ichthys Onshore LNG Facilities Emergency Response Plan (Document L290-AH-PLN-0055 (JKC Australia LNG Pty Ltd,

2014) is provided as an attachment in Appendix D.


Status Compliant.

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3. EARLY SURRENDER OF LICENCE

15. Condition Any reports, records or other information required or able to be provided by the licensee under this licence must be

submitted to the administering agency prior to the licensee surrendering the licence. If the date on which a report,

record or other information is required falls after the date the licensee requests to surrender this licence, the licensee

must provide the report, record or information as far as possible using data available to the licensee up to and

including the date the request to surrender the licence is made.

How Desktop review

Evidence The licensee operated under the approval of WDL 211-4 during the reporting period. The WDL 211-4 has not been

surrendered to date.


Status Compliant.

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4. OPERATIONAL

16. Condition The Licensee must, without limiting any other condition of this Licence, in conducting the activity do all things

reasonable and practicable to ensure the activity does not adversely affect the Declared Beneficial Uses and

Objectives as declared from time to time, including those applying to the Darwin Harbour Region

How Desktop review.

Evidence A discharge toxicity risk assessment was undertaken for key discharge pathways, when spent water is discharged to Darwin

Harbour and was presented to administering agency with the Licence Application Supporting Information (EMP).

The assessment was conducted for the purpose of evaluating the potential risk to the beneficial uses identified for Darwin

Harbour/Elizabeth River associated with the proposed discharge of spent waters. In addition, Section 4.1 of the HEMP

addresses the key activities, potential impacts and residual risk levels identified during the pre-commissioning environmental

hazard identification (ENVID) workshops. The residual risk levels for key activities have been summarised in Table 4.1 of the

HEMP. The detailed risk assessment is aligned with the mixing zone management approach as defined in Australian and New

Zealand Guidelines for Fresh and Marine Water Quality (Australian and New Zealand Environment and Conservation Council

[ANZECC] and the Agriculture and Resource Management Council of Australia and New Zealand [ARMCANZ], 2000a)

(ANZECC Guidelines) and the Guidelines on Mixing Zones (NT EPA, 2013). The licensee undertakes all discharge operations

in accordance with the HEMP, which specifies the mitigation measures and controls that have been developed and are

implemented during operations to reduce those risks identified such that ‘Residual Risks’ of environmental harm are reduced

to as low as reasonably practicable.

The design of the MOF diffuser outfall has been established to achieve conservative mixing and dilution for all discharges via

authorised discharge location DL2. This provides a low risk of adversarial impacts on the beneficial uses and minimises the

risk of environmental harm to the sensitive ecosystems. The outfall diffuser is an engineered solution, which provides an

additional safety margin for diluting spent waters to below laboratory detection limits within the 50 m mixing zone in the

receiving environment.

Sampling and analysis of all spent waters proposed for discharge is undertaken. The results are used to assess the quality of

water proposed for discharge prior to discharge authorisation, in accordance with the HEMP and the Project’s Water

Discharge Procedure (L290-AB-PRC-10265) (WDP), and provides an early warning indicator of the risk of potential impacts

from discharge.

Surface water compliance monitoring is undertaken in accordance with the HEMP and WDL 211-4 Conditions. During the

current reporting period, there were 98 monitoring events carried out under seven discharge permits via authorised discharge

location DL2.

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Results of the monitoring program undertaken during the reporting period, including data interpretation and long-term trend

analyses, are detailed in Greencap Pty Ltd, 2018a. Analysis of data for the annual reporting period and since the

commencement of discharge operations under WDL 211 (as amended), indicated water quality measured at the edge of the

regulatory mixing zone was representative of the upper reaches of the Darwin Harbour estuarine environment.

Water quality parameters were relatively consistent across impact sites and upstream/downstream reference sites and were

generally within expected ranges.

Seasonal Mann-Kendall trend analysis indicated that there were no significant increasing or decreasing trends in water quality

parameters over the period that data have been collected, with the exception of total suspended solids (TSS) which showed

an increasing trend at a single impact site and at one reference site.

Parameter concentrations at impact sites and the downstream reference site did not show responses to increases or

decreases in discharge volumes, or a response to spent water quality fluctuations over the long term. Further, parameter

concentrations in the receiving environment generally remained within the long term seasonal 80th percentile for Darwin

Harbour. The results indicated that discharged wastewater was not influencing water quality in the marine receiving

environment.

Spent waters discharged from the authorised discharge point (outfall diffuser) achieved the end of pipe criteria on the majority

of occasions. Discharged waters and waters in the receiving environment at the edge of the outfall mixing zone did not:

contain any visible matter, petroleum hydrocarbon sheen or scum, or litter or other objectionable matter;

cause or generate odours which would adversely affect the use of surrounding waters;

cause algal blooms;

cause visible change in the behaviour of fish or other aquatic organisms;

cause mortality of fish or other aquatic organisms; or

cause adverse impacts on plants.

The monitoring data, collected from the commencement of WDL211 (as amended) operations, from August 2016 to July 2018,

confirms that the Declared Beneficial Uses and Objectives of the subject waterways have not been adversely affected by the

Licensed Activity.


Status Compliant.

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17. Condition The licensee must do all things reasonable and practicable to:

17.1 maximise the re-use of spent hydrotest water and construction wastewater; and

17.2 minimise the volume of wastewater discharged to Darwin Harbour

How Desktop review.

Evidence The HEMP specifies that wherever possible, spent waters that comply with re-use water quality criteria

(Table 6.4) will be reused on-site for pre-cleaning, flushing or further hydrotesting, dust suppression, compaction or soil

amelioration purposes.

Dewatering permits specify the dewatering method of spent waters as either “discharge” or “reuse.” For all dewatering

operations, where water quality achieves the criteria specified in Table 6.4 of the HEMP and WDP, reuse options are

considered and detailed within the permit, with water quality data attached. For example, Permit Doc No. 004007 (Surface

Water DWP) indicates that the dewatering method as “Reuse” and includes the following description, “Water Tank to be

emptied and water to be used for dust suppression.”

The Project has reused spent waters to the maximum extent possible and reasonable and practicable measures have been

implemented to maximise the re-use of spent waters and minimise the volume discharged to Darwin Harbour.

Examples of dewatering permits, as evidence for the implementation of re-use options, are included in Appendix E.


Status Compliant

18. Condition The licensee must ensure any plant and equipment used by the licensee in conducting the activity:

18.1 is fit for the purpose and use to which it is put;

18.2 is maintained; and

18.3 is operated by a person trained to use the plant and equipment.

How Desktop review.

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Evidence All plant and equipment used on the Ichthys Onshore LNG Facilities are subject to strict quality control requirements under a

Project-wide Quality Control Plan (L290-AQ-PLN-003) and various associated procedures. The general requirements of the

plan (and associated procedures) are to assure that the workmanship, equipment and materials conform to the Project

requirements and that personnel are competent in their use. Inspections and testing of general equipment, including pumps

and hoses, are undertaken prior to being authorised for use on the Project. Project personnel are required to undertake

training and competency is validated via Verification of Competency (VOC) assessments prior to being approved to operate

plant and equipment.

The design of the MOF diffuser outfall has been established to achieve conservative mixing and dilution for all discharges via

authorised discharge location DL2. This provides a low risk of adversarial impacts on the beneficial uses and minimises the

risk of environmental harm to the sensitive ecosystems. The outfall diffuser is an engineered solution, which provides an

additional safety margin for diluting the spent hydrotest waters to below laboratory detection limits within the 50 m mixing zone

in the receiving environment. The diffuser design and outfall piping plan is provided in Appendix F and once installed, requires

minimal maintenance. It is a closed system with one way diffuser ports, preventing the potential for biofilm growth within the

outfall pipework and thus pigging the pipes is not a requirement during operations.

With the exception of general servicing and maintenance of pumps, power supply equipment and pipe coupling replacements,

no rectification works were required during the current reporting period.

Thus, all plant and equipment used by the licensee in conducting the activity is considered fit for purpose, adequately

maintained and operated by competent persons at all times.


Status Compliant

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5. DISCHARGES

19.

Condition This licence authorises discharge of

19.1 Spent Hydrotest Water to Authorised Discharge Location DL1 as described in Table 2 and Appendix 1 of this

licence; and

19.2 Spent Hydrotest Water or Construction Wastewater to Authorised Discharge Location DL2 as described in

Table 2 of this licence.

Table 2: Authorised Discharge Locations

Discharge Locations Description Location

Latitude Longitude

DL1

Regulating drain to Darwin Harbour from

north east corner of the premises;

comprising 48 outfall pipes spaced every

3 metres.

12.51350°S to

12.51120°S

12.51111°S to

12.51184°S

130.92223°E to

130.92096°E

130.92053°E to

130.991916°E

DL2 Temporary outfall and diffuser near

Module Offloading Facility (MOF). 12.51167°S 130.92621°E

How Desktop review.

Evidence Diffuser design plans are included as Appendix F and identify the latitude and longitude of the MOF diffuser. Appendix 1 of

WDL211-4 includes coordinate locations of DL1 regulating reservoir outlets at the North East corner of the Site.

All authorised discharges during this monitoring period occurred via the MOF outfall (Location DL2) and comprised spent

construction and commissioning waters as authorised by this Licence.

Discharge location DL1 was not utilised for authorised discharge during the reporting period. An unauthorised discharge event

occurred on 6 July 2018 where a coupling on the MOF discharge line became loose, resulting in the passive discharge of

approximately 20 kL of spent potable water from commissioning activities to the receiving environment via the regulating drain

(non-compliance notification reference PRL7251, refer to Condition 21 for detailed information).

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Status Compliant.

20. Condition The licensee must ensure that all discharge events at each authorised discharge location consists only of waste from

the source as specified in Table 2.


Evidence All authorised discharges during the reporting period occurred via the MOF outfall (Location DL2) and all comprised spent

waters from testing and commissioning activities relating to construction, commissioning and pre-start of the Ichthys Onshore

LNG Facility at Bladin Point, in accordance with the Licenced Activity and the authorisation specified in Table 2 of WDL211-4.

Dewatering permits, issued for each authorised discharge via Location DL2 in accordance with the Project’s Water Discharge

Procedure (WDP) during the reporting period, are provided in Appendix G. Each dewatering permit specifies the spent

wastewater source and a review of the documentation confirms discharge from Location DL2 consisted only of waste as

authorised by WDL211-4.

There were no authorised discharges to spent waters to the Authorised Discharge Location DL1 (regulating drain) during the

reporting period. An unauthorised discharge event occurred on 6 July 2018 where a coupling on the MOF discharge line

became loose, resulting in the passive discharge of approximately 20 kL of spent potable water from commissioning activities

to the receiving environment via the regulating drain (non-compliance notification reference PRL7251, refer to condition 21 for

detailed information).


Status Compliant.

21. Condition The licensee must ensure that prior to the release of Spent Hydrotest Water to the regulating drain within authorised

discharge location DL1:

21.1 the quality of Spent Hydrotest Water, does not exceed the water quality limits specified in Column 4 of Appendix

3 of this licence; and

21.2 the Spent Hydrotest Water does not contain any chemicals or substances that have potential to be harmful to

the Beneficial Uses and Objectives for Darwin Harbour.

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Evidence There were no authorised discharges to spent waters to the Authorised Discharge Location DL1 (regulating drain) during the



to the receiving environment via the regulating drain (non-compliance notification reference PRL7251, refer to condition 37).

A review of spent water characterisation results, available for characterisation sampling undertaken on 3 July 2018 and

considered representative of the spent waters inadvertently discharged, observed concentrations of ammonia (at 57 µg/L) and

zinc (at 28 µg/L) that exceeded Limits for Discharge to Regulating Reservoir (prior to discharge via DL1) specified in Column 4

of Appendix 3 of WDL211-4.

Response monitoring was initiated on 6 July 2018 and comprised the collection of a sample of spent waters direct from the

loose coupling at three locations within the receiving environment at the points of discharge from the regulating drain. The

subsequent environmental assessment concluded:

The leak water spill released from the MOF line contained exceedances of oxides of nitrogen, filterable reactive

phosphorus (FRP), total suspended solids (TSS) and Zinc for authorised discharge to Location DL1, and this was a

trigger of WDL 211-4 Condition 21.1.

Only one analyte, TSS, also exceeded in the receiving environment sampling. However, the concentration of TSS was

lower in the leak water than in the receiving environment and therefore excluded the discharge as being the source of

the TSS exceedance observed in the receiving environment.

Total phosphorus in the leak water did not exceed the approved criteria in WDL 211-4 and following 1:5 dilution that

occurred as the discharge was released over the rock armour and into Darwin Harbour, would not be sufficient to be

the source of the elevated phosphorus observed in the receiving environment.

To put these results into context, control charts were prepared (with reference to Section 6.4.3.3, of the ANZECC

monitoring and reporting guidelines), which compares the receiving environment TSS and phosphorus exceedances

with the long term 80th percentile for the dry season reference site data collect from the Environmental Impact

Monitoring Program (EIMP). The reference data has been collected from the four EIMP reference sites and the

upstream reference sites from the Jetty Outfall, WDL 211-4 and the WDL 192-3 monitoring programs.

Based on the receiving environment results there were slight exceedances of the 80th percentile for oxides of nitrogen

(at 1 location) and for TSS, phosphorus and arsenic (at all 3 locations). It is noted that the 80th percentile is calculated

using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally,

whereby the 80th percentile warns when we are approaching the maximum seasonal values previously seen at the

reference sites. Further review of the chart showed that the reference sites also exhibited oxides of nitrogen, TSS,

phosphorus and arsenic concentrations above the 80th percentile value at times during the 2016, 2017 and 2018 wet

seasons and also during 2018 dry season.

INDRA28-SEP-2018




The spill of 20 kL was of a limited duration and would have been substantially diluted by the diurnal tides that have

occurred since the event.

Therefore, the potential for environmental harm to the receiving environment receptors (water column, soft bottom

benthic) associated with the discharge is negligible. The exceedances observed at the mixing zone monitoring

locations were not believed to be attributable to the MOF spill event. The contributing factors associated with the non-

compliance are attributed to heterogeneity in the sampling of waters associated with Darwin Harbour seasonal cycles,

with no associated risk of environmental harm.


Status Compliant.

22. Condition The licensee must ensure that the flow rate of discharge to authorised discharge location DL1 does not exceed

0.5m3/s into each independent section of the regulating drain.


Evidence There were no authorised discharges to spent waters to the Authorised Discharge Location DL1 (regulating drain) during the



to the receiving environment via the regulating drain (non-compliance notification reference PRL7251, refer to conditions 19-21

and 37).

The discharge line was not under pressure when the incident occurred, resulting in a slow passive discharge to the regulating

drain and subsequent diffuse discharge to the receiving environment via multiple regulating drain outlets. As such, the passive

discharge of these waters would not have resulted in flow rates from each independent section of the regulating drain

exceeding 0.5m3/s.


Status Compliant.

INDRA28-SEP-2018




23. Condition The licensee must ensure that discharge from Authorised Discharge Location DL2 does not cause the median

surface water quality of the monitoring sites specified in Table 3 to exceed, the water quality trigger for any of the

water quality parameters specified in Column 5 of Appendix 3:

23.1. on three consecutive occasions, and the exceedance is also not present at the upstream site determined from

the tide phase at the time of sampling, on the same three consecutive occasions; or

23.2. a single occasion where the measured value exceeds the trigger value greater than or equal to two times the

trigger value and the exceedance is not also present at the upstream site, determined from the tide phase at the time

of sampling.

Table 3: Monitoring Sites for Authorised Discharge Location DL2

MOF Monitoring Sites

Location

Latitude Longitude

HYDRO-01 12.51209°S 130.92604°E

HYDRO-02 12.51132°S 130.92593°E

HYDRO-03 12.51144°S 130.92661°E

How Desktop review.

Evidence The HEMP details the management controls implemented to achieve compliance with Condition 23 and include:

Installation of a diffuser designed to achieve at least 74-fold dilution for the most conservative parameter within a 50 m

mixing zone at the outfall;

End of pipe monitoring of the spent waters prior to discharge (as per the Project’s Water Discharge Procedure (WDP)).

End of pipe results are used to assess the quality of water proposed for discharge prior to discharge authorisation, and

provides an early warning indicator of the risk of potential impacts from discharge; and

Targeted sampling in the receiving environment during discharge operations, to validate water quality at the edge of the

mixing zone.

Targeted sampling is required to assess whether Condition 23 is being met. Water quality monitoring, undertaken during

discharge to the receiving environment and reported within Greencap, 2018a), confirms that on eight separate occasions,

INDRA28-SEP-2018




water quality measured at the MOF Monitoring Sites triggered Condition 23.2 during the reporting period. These exceedances

were greater than or equal to two times the trigger criteria and were reported as non-compliances to the NT EPA. These non-

compliant exceedances included:

TSS (20 mg/L) on 1 September 2017;

Filtered copper (3 µg/L) on 13 September 2017;

Total phosphorus (100 µg/L) on 30 October 2017;

Chlorophyll-a (8.9 µg/L) 27 November 2017;

Oxides of nitrogen (57 µg/L) on 18 December 2017;

TSS (24 mg/L) on 7 March 2018;

Filtered copper (4 µg/L) on 14 April 2018; and

Oxides of nitrogen (52 µg/L) on 19 July 2018.

Each trigger of Condition 23.2 of WDL211-1 were risk assessed in regard to their likely cause and potential impacts on the

Beneficial Uses of Darwin Harbour, as follows:

Spent water discharge concentrations, measured prior to discharge, were reviewed and compared to the end of pipe

trigger criteria and to the receiving environment concentrations;

Impact site concentrations were compared to upstream and downstream reference site concentrations;

Impact site concentrations were compared to the monthly monitoring data that were collected as part of the

Environmental Impact Monitoring Program (EIMP) conducted in accordance with EPA7 (as amended); and

For each exceedance, control charting was used to compare the exceedance concentration with the long term 80th

percentile, in accordance with ANZECC Guidelines (section 6.4.3.3). Exceedances were compared against the 80th

percentiles to assess whether the data remains within the long term seasonal variation.

The outfall diffuser has been designed to ensure a minimum dilution of 74-fold within the mixing zone. As such, the

concentrations of the above parameters within spent waters, as measured prior to discharge, would not have been sufficient to

have caused the exceedances at the impact sites at the edge of the mixing zone. It was therefore concluded that the

discharges were not the cause of the reportable exceedances at the impact sites and no further action, in the form of response

monitoring, was required.

Results of the monitoring program undertaken during the reporting period, including data interpretation and trend analyses, are

detailed in Greencap, 2018a.


Status Compliant.

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24. Condition The licensee must ensure that the discharge from all discharge events at each authorised discharge location does

not:

24.1. contain any floating debris, oil, grease, petroleum hydrocarbon sheen, scum, litter or other objectionable

matter;

24.2. cause or generate odours which would adversely affect the use of surrounding waters;

24.3. cause algal blooms in the receiving water;

24.4. cause visible change in the behaviour of fish or other aquatic organisms in the receiving water;

24.5. cause mortality of fish or other aquatic organisms; or

24.6. cause adverse impacts on plants.

How Desktop Review

Evidence Surface water compliance monitoring was conducted during the reporting period in accordance with WDL 211-4.

Field observations were recorded during each monitoring event both in relation to spent waters prior to discharge and in the

receiving environment during discharge. There were no records of discharge resulting in visible matter, petroleum hydrocarbon

sheen or scum, litter or other objectionable matter within the receiving environment. There was no evidence of wastewater

discharge causing or generating odours which would adversely affect the use of surrounding waters. There was no evidence

of algal blooms, abnormal fish behaviour or mortality and no evidence of adverse impacts on marine and intertidal plant

species.

Field observations recorded during monitoring are detailed in Greencap Pty Ltd, 2018a and field records are given in Appendix

B of the report.


Status Compliant.

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6. MONITORING

25. Condition The licensee must conduct surface water monitoring in accordance with Appendix 3.

How Desktop review and compilation of Greencap, 2018a.

Evidence Results of the monitoring program undertaken during the reporting period are detailed in Greencap Pty Ltd, 2018a which

confirms that surface water monitoring was undertaken in accordance with Appendix 3 of WDL 211-4 during the reporting

period.

When (Date) Surface water compliance monitoring undertaken per Appendix 1 of WDL 211-4 during the reporting period.

Status Compliant.

26. Condition The licensee must for all land based monitoring points specified in Appendix 3:

26.1. install and maintain appropriate identification signage so that they are reasonably identifiable at all times; and

26.2. maintain safe access and egress, as is reasonably practicable.

How Site inspection.

Evidence Visible markers have either been attached to the railings along MOF catwalks using high visibility tape, or spray painted on

concrete where appropriate, to identify the monitoring points for sample collection. Access to the monitoring points is via

secure catwalk ramps over the water and behind a secured railing on the edge of the MOF platform.

Refer to photograph given in Appendix H.

When (Date) Site inspection completed on 28/08/2018.

Status Compliant.

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27. Condition The licensee must ensure that all water samples and field environmental data are representative of the conditions at

the time of sampling

How Surface Water Monitoring Program, as per Appendix 3 of WDL 211-4.

Evidence Sample and in-situ data collection under WDL 211-4 during the reporting period was undertaken as per the methodology

prescribed for offshore surface water monitoring within the EIMP (as amended), which was developed in accordance with

recognised Australian Standards and guidelines, ensuring representative data. Refer to Condition 28 for a detailed description

of monitoring methodology.

Results of the monitoring program undertaken during the reporting period are detailed in Greencap Pty Ltd, 2018a.

A review of the monitoring methodology and data, including a review of QAQC measures, is presented in Section 5.4 of the

report and confirms that samples and field environmental data were collected in accordance with recognised Australian

Standards and guidelines, representative of the conditions at the time of sampling and were considered to be of acceptable

quality for the purposes of the monitoring program.


Status Compliant.

28. Condition The Licensee must ensure that all samples and field environmental data are collected in accordance with recognised

Australian Standards and guidelines (such as AS/NZS 5667, ANZECC/ARMCANZ).


Evidence Sample and in-situ data collection under WDL 211-4 during the reporting period was undertaken as per the methodology

prescribed for offshore surface water monitoring within the EIMP (as amended), which was developed in accordance with

recognised Australian Standards and guidelines, including:

AS/NZS 5667.1:1998 Water quality – Sampling ‘Part 1: Guidance on the design of sampling programs, sampling

techniques and the preservation and handling of samples’;

AS/NZS 5667.4:1998 Water quality – Sampling ‘Part 4: Guidance on sampling from lakes, natural and man-made’;

AS/NZS 5667.6:1998 Water quality – Sampling ‘Part 6: Guidance on sampling of rivers and streams;

AS/NZS 5667.9:1998 Water quality – Sampling ‘Part 9: Guidance on sampling from marine waters’.

The key procedures undertaken in the field are described below:

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Visual inspection of surface water collection points to determine the presence or absence of oil, grease, iron floc and floating matter;

In situ quality measurements (pH, total dissolved solids [TDS], electrical conductivity [EC], dissolved oxygen [DO], temperature, turbidity and oxidation reduction potential [ORP]) are undertaken prior to sample collection using a multi-parameter instrument. All field equipment are calibrated in accordance with the manufacturer’s instructions;

Collection of surface water samples and field QAQC samples for laboratory analysis after field quality parameter measurement;

Decontamination of all non-dedicated sampling equipment between sample locations; and

Proper disposal of used disposable sampling equipment.

At each surface water sampling location, the field records include the following minimum information:

Exact location (sample point number/name and/or GPS coordinates), sampling time, date and the name of the sampler(s);

Sample type, number of containers, sample preservatives and sample collection order;

Weather conditions;

Sample collection equipment and method;

Purging records, for example, water quality meter calibration records;

Sample equipment decontamination procedures, where non-disposable sampling equipment is utilised; and

Any comments on exceptions or issues regarding the sample collected.

Each sample label includes the following information:

Subcontractor and sampler's name;

Sample point identification and unique sample number;

Date and time sample was taken; and

Whether the sample was field filtered.

Field instruments, including the pH probe, EC probe, turbidity meter and DO meter, are calibrated as per the manufacturer's

instructions and Australian Standards prior to each sampling day and in the event of unusual sampling results. Equivalent

calibrated backups units are available on the same day for all field equipment so that equipment failures do not result in data

gaps.

A chain of custody (CoC) form is completed to accompany the samples to the laboratory for submission for analysis.

In each instance, the following are undertaken:

The CoC form is completed in pen;

All information requirements are completed on the form;

All eskies are dispatched under seal of custody to the nominated laboratories;

The CoC form conveys instructions to the laboratory, such as analyses to be performed, field preparation (filtered or

INDRA28-SEP-2018




not filtered, as applicable, etc.) and sample analysis turnaround times required to be achieved;

On delivery to the laboratory, the receiving person inspects the eskies, notes the presence or otherwise of ice or freezer bricks if specified on the CoC form, measure the temperature and record each entry on the relevant CoC form;

The completed CoC form is transmitted to Subcontractor within 24 hours of the delivery of samples to the laboratory; and

CoC forms are presented with the original laboratory certificates in monitoring reports.

The selection of the appropriate sample containers, preservation procedures, sample storage requirements and holding times

are undertaken in accordance with those recommended by AS/NZS 5667.1:1998 Water Quality Sampling – Guidance on the

design of sampling programs, sampling techniques and the preservation and handling of samples. All primary samples and

associated QAQC samples are shipped to the laboratory to ensure holding times are achieved, when practicable. The

laboratory is notified of the shipment of samples and their expected arrival.

All samples are refrigerated during the course of the working day and in transit to the laboratory in cooler boxes packed with

ice or cooling blocks. Nominated laboratories are instructed to retain all the sampling extracts obtained for the analysis of

organic parameters to be kept under refrigeration for at least 30 days after the issue of the laboratory report. This allows time

for the laboratory report to be reviewed and repeat tests or additional tests, to be conducted within the extract holding time.

Laboratory reports are issued in accordance with the requirements of National Association of Testing Authority (NATA)

endorsement and, as a minimum, include the following information appended within the monitoring report:

The test results for the samples;

The test results for the laboratory’s in-house duplicates;

The test results for the laboratory’s in-house surrogate and matrix spike recovery determinations; and

The extraction (where applicable) and analysis dates which would be used to determine compliance with the permitted holding times.

Surface water quality control samples are collected at the following frequencies:

Field duplicate (intra laboratory duplicates) samples at least one per 20 monitoring events;

Field triplicate (inter laboratory replicates) samples at least one per 20 monitoring events;

Field blank samples at one per day and field rinsate samples at one per day; and

Trip blanks one per cooler box containing samples scheduled for benzene, toluene, ethylbenzene and xylene (BTEXN) analysis.

The laboratory selected to conduct the analysis of surface water samples are accredited by NATA and able to demonstrate

that it can achieve the required analytical LOR and quality. Furthermore the following QAQC procedures are used:

Analyses are reviewed by NATA and meet NATA accreditation parameters, which meet ISO/IEC 17025:2005 General requirements for the competence of testing and calibration laboratories (ISO/IEC 17025) and ISO 9001:2008 Quality

INDRA28-SEP-2018




management systems – requirements (ISO 9001). In addition, the laboratory’s QAQC procedures are reviewed by external consultants on an annual basis;

Method blanks are processed and analysed to detect any contamination resulting from sample preparation, extraction or analysis. After each batch of samples is analysed, a blank sample is run to see if this returns a value below or near the detection limit of the analytical technique;

The samples are split into sub-samples to check the precision of the analyses at a duplication of 10%;

Surrogate spikes are undertaken, with one sample in every batch spiked. As a known quantity of a surrogate is added to each sample prior to extraction, the quantity of surrogate recovered after the analytical process provides a measure of analytical performance;

Matrix spikes are analysed with at least one sample in every sample batch spiked. As a known quantity of the analyte is added to each sample prior to extraction, the quantity of analyte recovered after the analytical process provides a measure of analytical performance;

Laboratory instruments are calibrated daily at the beginning of each process batch of analyses on a specific analyser. A continuing calibration verification is run at a minimum frequency of one in every 20 samples or at least one per each process batch of analyses on a specific analyser. Control figures are produced weekly to identify outliers or possible trends for particular tests or instruments; and

The laboratory is certified by NATA to conduct the specific tests required, unless NATA does not certify a particular analysis or method specified in this plan. In the instances where NATA accreditation is not available, standard industry practice is applied.







Status Compliant.

29. Condition The licensee must ensure all samples collected in accordance with this licence, are obtained by, or under the

supervision of a qualified sampler.

How Desktop review.

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Evidence The WDL 211-4 compliance monitoring program is undertaken by independent, trained, qualified and experienced

environmental scientists in accordance with standard monitoring procedures that are aligned with industry best practice and

standards, including:

Australian and New Zealand Guidelines for Fresh and Marine Water Quality (Australian and New Zealand

Environment and Conservation Council [ANZECC] and the Agriculture and Resource Management Council of

Australia and New Zealand [ARMCANZ], 2000a) (ANZECC/ARMCANZ 2000a);

Australian Guidelines for Water Quality and Reporting (ANZECC/ARMCANZ, 2000b);

AS/NZS 5667:1:1998 Water Quality Sampling – Guidance on the design of sampling programs, sampling techniques

and the preservation and handling of samples (AS/NZS 5667.1);

AS/NZS 5667.4:1998 Water Quality Sampling – Guidance on sampling from lakes, natural and man-made (AS/NZS

5667.4);

AS/NZS 5667.6.1998 Water Quality Sampling – Guidance on sampling of rivers and streams (AS/NZS 5667.6);

AS/NZS 5667.9.1998 Water Quality Sampling – Guidance on sampling from marine waters (AS/NZS 5667.9);






Curriculum Vitae’s (CVs) of sampling personnel can be provided upon request.


Status Compliant.

30. Condition The Licensee must ensure that all monitoring samples are analysed at a laboratory with current NATA accreditation

or equivalent, for the parameters to be measured.


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Evidence The primary laboratory used for sample analyses during the reporting period was Eurofins|MGT Pty Ltd (MGT), while the

secondary laboratory was ALS Global Pty Ltd (ALS). Both laboratories are accredited by NATA for all water quality parameters

required under WDL 211-4 and were able to demonstrate that they achieved the quality assurance and quality control

requirements under the accreditation. Furthermore, the following QAQC procedures were adopted in accordance with their

NATA accreditation:

Analyses are reviewed by NATA and meet NATA accreditation parameters, which meet ISO/IEC 17025:2005 General requirements for the competence of testing and calibration laboratories (ISO/IEC 17025) and ISO 9001:2008 Quality management systems – requirements (ISO 9001). In addition, the laboratory’s QAQC procedures are reviewed by external consultants on an annual basis;

Method blanks are processed and analysed to detect any contamination resulting from sample preparation, extraction or analysis. After each batch of samples is analysed, a blank sample is run to see if this returns a value below or near the detection limit of the analytical technique;

The samples are split into sub-samples to check the precision of the analyses at a duplication of 10%;

Surrogate spikes are undertaken, with one sample in every batch spiked. As a known quantity of a surrogate is added to each sample prior to extraction, the quantity of surrogate recovered after the analytical process provides a measure of analytical performance;

Matrix spikes are analysed with at least one sample in every sample batch spiked. As a known quantity of the analyte is added to each sample prior to extraction, the quantity of analyte recovered after the analytical process provides a measure of analytical performance;

Laboratory instruments are calibrated daily at the beginning of each process batch of analyses on a specific analyser. A continuing calibration verification is run at a minimum frequency of one in every 20 samples or at least one per each process batch of analyses on a specific analyser. Control figures are produced weekly to identify outliers or possible trends for particular tests or instruments; and

The laboratory is certified by NATA to conduct the specific tests required, unless NATA does not certify a particular analysis or method specified in this plan. In the instances where NATA accreditation is not available, standard industry practice is applied.


The NATA accredited laboratory test reports, inclusive of sample receipt notices and QAQC reports, are provided in Appendix

D of the report.

The NATA accreditation for Eurofins|MGT Pty Ltd (MGT) (accreditation No. 1261) and ALS Global Pty Ltd (ALS) (accreditation

No. 825) are available to view on the NATA website via https://www.nata.com.au/nata/


INDRA28-SEP-2018


https://www.nata.com.au/nata/



Status Compliant.

31. Condition The licensee must ensure that, for each sample collected in accordance with this licence, the following information is

recorded and retained:

31.1 the date on which the sample was collected;

31.2 the time at which the sample was collected;

31.3 the location at which the sample was collected;

31.4 the name of the person who collected the sample;

31.5 the field measurements relating to the sample including, tide stage (rising, falling, maximum, minimum), tide

range and time since the maximum tide was reached;

31.6 the time the discharge commenced and the duration of the discharge;

31.7 the discharge flow rate;

31.8 the discharge volume;

31.9 all chemicals added to the hydrotest water and construction wastewater and dosage used;

31.10 recycling and re-use options considered, and the reason why the wastewater was not recycled or re-used;

31.11 the chain of custody forms relating to the sample;

31.12 analytical results (if any) relating to the sample; and

31.13 laboratory quality assurance and quality control documentation.

How Desktop review.

INDRA28-SEP-2018




Evidence Field records are collected at each monitoring location during each monitoring event. Information recorded includes, but is not

limited to:

the date(s) on which the sample was taken;

the time(s) at which the sample was collected;

the point(s) at which the sample was taken;

the name of the person who collected the sample; and

the field measurements for the sample.

A CoC form is completed to accompany the samples to the laboratory for submission for analysis. In each instance, the

following procedures are undertaken:

The CoC form is completed in pen;

All information requirements are completed on the form;

All eskies are dispatched under seal of custody to the nominated laboratories;

The CoC form conveys instructions to the laboratory, such as analyses to be performed, field preparation (filtered or not filtered, as applicable, etc.) and sample analysis turnaround times required to be achieved;

On delivery to the laboratory, the receiving person inspects the eskies, note the presence or otherwise of ice or freezer bricks if specified on the CoC form, measure the temperature and record each entry on the relevant CoC form;

The completed CoC form is transmitted to Subcontractor within 24 hours of the delivery of samples to the laboratory; and

CoC forms are presented with the original laboratory certificates in monitoring reports.

Results of the monitoring program undertaken during the reporting period are detailed in Greencap Pty Ltd, 2018a. Tabulated

analytical results, including tide information at the time of sampling, are given in Appendix C of the report, field records

collected for each monitoring event are given in Appendix B of the report, CoC forms and laboratory test certificates, inclusive

of the laboratories internal QAQC documentation are given in Appendix D of the report. A review of the monitoring

methodology and data, including a review of QAQC measures, is presented in Section 5.4 of the report.

Discharge information is recorded in electronic dewatering permits (Appendix G), which are completed by subcontractors

prior to and following discharge, in accordance with the WDP.


Status Compliant.

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32. Condition The licensee must implement and maintain an environmental monitoring program to demonstrate that:

32.1 the composition of all discharges is properly characterised prior to discharge and all additives have been

identified and measured;

32.2 the discharge does not cause any short term or long term adverse impacts to the receiving environment,

including:

i. mangrove and intertidal ecosystems;

ii. aquatic ecosystem;

iii. recreational and aesthetic values;

32.3 all discharges comply with licence requirements.

How Surface water compliance monitoring undertaken per Appendix 3 of WDL 211-4 during the reporting period.

Environmental Impact Monitoring Program in accordance with EPA7 (as amended).

Evidence A monitoring program is undertaken in accordance with the HEMP and WDL 211 (as amended). The monitoring program has

been implemented, maintained and followed since the commencement of the Licenced Activity under WDL 211. All procedures

required by the HEMP and WDL 211 (as amended) are conducted by subcontractors in relation to water quality monitoring and

discharge operations.

Spent waters are assessed prior to discharge with results used to assess the quality of water proposed for discharge prior to

discharge authorisation, in accordance with the HEMP and the Project’s Dewatering Permit Procedure, with laboratory

certificates attached to each permit. The permit system also requires subcontractors to identify and measure any additives to

applied to the spent waters prior to discharge authorisation.

Results of the monitoring program undertaken during the reporting period, in accordance with the HEMP and WDL 211 (as

amended), are detailed in Greencap, 2018a with dewatering permits provided in Appendix E of the report and are also

provided in Appendix G of this Annual Return. The conclusions presented demonstrate:

The monitoring program has been successfully implemented and in full accordance with the HEMP and the Conditions

of WDL 211-4;

The composition of all discharges were properly characterised prior to discharge and any additives applied to spent

waters were identified and measured as part of the permit process prior to discharge authorisation; and

That discharges have not had a deleterious impact on the marine environment or their values during the reporting

period.

INDRA28-SEP-2018




Further, The Ichthys Onshore LNG Facilities - Construction Environmental Management Plan (INPEX Operations Australia Pty

Ltd, 2017) (L092-AH-PLN-10001) (CEMP) was prepared for the Site following development approval (Northern Territory [NT]

Government Development Permit DP12/0065B) to address the site-specific environmental risks associated with the Project.

The CEMP details the environmental protection management measures and controls necessary to avoid, reduce or mitigate

environmental impacts during the construction, pre-commissioning, commissioning and demobilisation phases of the Project,

inclusive of discharge activities.

Greencap was appointed by Contractor to implement the Environmental Impact Monitoring Program (Greencap Pty Ltd, 2017)

(L290-AH-PLN-10013) (EIMP [Rev 10]) for the Project, which was prepared in order to meet Condition 21 of the Environment

Protection Approval for the Project (EPA7) (as amended). The EIMP establishes the monitoring framework for the detection of

potential impacts associated with the construction of the Project, inclusive of discharge activities.

The Annual Environmental Monitoring Report 2018 - Environmental Impact Monitoring Program (Greencap Pty Ltd, 2018c)

(L290-AH-REP-10884) (AEMR [2018]) and provides an assessment of all environmental monitoring results and trends for the

period from 1 May 2017 to 30 April 2018 (the annual monitoring period), inclusive of mangrove, intertidal and aquatic

ecosystems. In addition, the report outlines any trends or patterns in the data compared to previous annual monitoring periods

and background data that may have been collected prior to the commencement of the Project.

In conclusion, the AEMR provided a clear understanding of the Project’s potential impacts on the adjacent receiving

environment and broader Darwin Harbour. While there were exceedances across a small range of the total number of

parameters measured during the annual monitoring period, it was assessed that these did not result in environmental harm in

the receiving environment. The environmental impacts and risks associated with the Project are adequately managed through

the provisions, procedures and mitigation measures outlined in the CEMP.


Environmental Impact Monitoring Program in accordance with EPA7 (as amended) during the reporting period.

Status Compliant.

33. Condition The licensee must demonstrate that wastewater discharged from the regulating reservoir at Authorised Discharge

Location DL1 for spent hydrotest wastewater will not cause environmental harm.

How Desktop review.

Evidence Refer to Conditions 19 to 22 (inclusive) for supporting evidence that discharge from Authorised Discharge Location DL1 has

not caused environmental harm.

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Status Compliant.

34. Condition The licensee must collect water samples and analyse the water samples for parameters specified in Appendix 3 at the

monitoring sites specified in Table 3 at the time wastewater is being released from Authorised Discharge Location

DL2.

How Desktop review.

Evidence Results of the monitoring program undertaken during the reporting period are detailed in Greencap Pty Ltd, 2018a and

confirms that surface water monitoring was undertaken in accordance with Appendix 3 of WDL 211-4 and at the sites identified

in Table 3 when discharging to discharge location DL2.


Status Compliant.

35. Condition The licensee must collect samples specified in condition 25 at least once every 48 hours during the discharge of

spent hydrotest or construction water to Authorised Discharge Location DL2.

How Desktop review.

Evidence Water samples were collected at least once every 48 hours during the discharge of spent waters under WDL 211-4.

Sampling dates are included on field records and laboratory CoC documentation, which illustrates the frequency of monitoring.

Results of the monitoring program undertaken during the reporting period are detailed in Greencap Pty Ltd, 2018a and

confirms that surface water monitoring was undertaken in accordance with the density as specified in this Condition.

During the current reporting period, a total of 98 monitoring events (undertaken in strict accordance with the Licence

Conditions) were undertaken during active discharge of spent waters from Authorised Discharge Location DL2.


Status Compliant.

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7. RECORDING AND REPORTING

36.

37.

38.

Condition(s) 36. The licensee must keep records of all non-compliances with this licence. These records must be adequate to

enable the licensee to comply with the non-compliance notification conditions of this licence.

37. The licensee must notify the administering agency of any non-compliance with this licence by emailing

[email protected], as soon as practicable after, and in any case within 24 hours after, first becoming aware of the non-

compliance.

38. The licensee must include in the notification of non-compliance the following information:

38.1 when the non-compliance was detected and by whom;

38.2 the date and time of the non-compliance;

38.3 the actual and potential causes and contributing factors to the non-compliance;

38.4 the risk of environmental harm arising from the non-compliance;

38.5 the action(s) that have or will be taken to mitigate any environmental harm arising from the non-compliance;

38.6 corrective actions that have or will be undertaken to ensure the non-compliance does not reoccur;

38.7 if no action was taken, why no action was taken;

38.8 a date when an incident investigation or incident closure report, if requested by the administering agency, will

be submitted to the administering agency.

How Desktop Review.

Evidence A desktop review has confirmed that all records of non-compliances with WDL 211-4 have been kept and filed. There were

eight non-compliances during the reporting period, all pertaining to Condition 23.3 where exceedances of trigger values, as

specified in Appendix 3 of WDL 211-4, were reported in the receiving environment.

Notification of the non-compliances were provided to NT EPA with the issue of an email to [email protected] within 24

hours of becoming aware. The NT EPA notifications are given in Appendix I.


Status Compliant.

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39. Condition The licensee must keep records of all exceedances of trigger values specified in Appendix 3. These records must be

adequate to enable the licensee to comply with the exceedances notification conditions of this licence.

How Surface water compliance monitoring undertaken per Appendix 3 of WDL 211-4 during the reporting period and desktop

review.

Evidence Refer to Conditions 36, 37 and 38.


Status Compliant.

40. Condition The licensee must investigate the cause of all events when the water quality of the water sample exceeded any of the

water quality trigger values specified in Appendix 3. These records must be adequate to enable the licensee to

comply with the exceedances notification conditions of this licence.

40.1 The investigation must be initiated by the licence holder as soon as possible after the sampling event and

receipt of results.

40.2 Exceedance events that do not trigger condition 23 must be reported to the administering agency annually with a

summary of the investigation findings.

How Desktop review.

Evidence All monitoring results are maintained in the form of an electronic register, which includes all physico-chemical and analytical

data (Refer to Appendix C of Greencap Pty Ltd, 2018a). This is updated as laboratory results are received and reviewed as

part of an internal quality assurance and quality control plan. Exceedances of trigger values, both at individual monitoring

locations and the median value of the three impact sites (inclusive), have been highlighted to aid identification.

In addition, when a non-compliance is observed, written notification is submitted along with the register including the details of

the non-compliance.

All reportable exceedances are risk assessed in regard to their likely cause and potential impacts on the Beneficial Uses of

Darwin Harbour, as follows:

Spent water discharge concentrations, measured prior to discharge, were reviewed and compared to the end of pipe

trigger criteria and to the receiving environment concentrations;

Impact site concentrations were compared to upstream and downstream reference site concentrations;

INDRA28-SEP-2018




Impact site concentrations were compared to the monthly monitoring data that were collected as part of the EIMP

conducted in accordance with EPA7 (as amended); and

For each reportable exceedance, control charting was used to compare the exceedance concentration with the long

term 80th percentile, in accordance with ANZECC Guidelines (section 6.4.3.3). The reference data for control charting

has been generated from four EIMP control sites and the upstream reference sites associated with the Jetty outfall,

WDL 211 and the WDL 192 monitoring programs. The WDL 211 impact site exceedances were compared against the

80th percentiles to assess whether the data remains within the long term seasonal variation.


Status Compliant.

41.

42.

43.

Condition(s) 41. The licensee must complete and provide to the administering agency an Annual Monitoring Report by the 30

September covering the period 1 August to 30 July, which relates to the preceding licence period.

42. The administering agency may require the licensee to revise or amend and resubmit any Monitoring Report.

Where the administering agency requires the Monitoring Report to be submitted the date will be specified and will

become a condition of this licence.

43. The licensee must ensure that each Monitoring Report:

43.1 is prepared in accordance with the requirements of the NT EPA ‘Guideline for Reporting on Environmental

Monitoring’;

43.2 includes a tabulation of all monitoring data required as a condition of this licence;

43.3 includes tabulation of the following parameters for each authorised discharge location;

i. total volume discharged

ii. discharge time periods

iii. total load of the water quality parameters prescribed to be measured;

43.4 includes long term trend analysis of monitoring data to demonstrate any environmental impact associated with

the activity over a minimum period of three years (where the data is available);

43.5 includes an assessment of environmental impact from the activity; and

43.6 includes assessment of compliance with conditions of this licence.

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How Desktop review.

Evidence Results of the monitoring program undertaken during the reporting period are detailed in Greencap Pty Ltd, 2018a, and will be

submitted to the NT EPA by 30/09/2018.

Tabulation of field results and analytical parameters are given in Appendix C of the report, and includes total discharge

volumes.

Long term trend analysis of monitoring data, to assess water quality trends since the commencement of monitoring associated

with discharge under WDL211 (as amended) is presented in Section 6.3 and Appendix F of the report. The trend analysis has

comprised assessment of seasonal variation, inter-annual oscillations, monotonic (significant increasing/decreasing) trends

and association between conditions within the receiving environment and wastewater discharge flows and concentrations.

A summary of the investigation, causes of an exceedance of the trigger values, and assessment of likely environmental impact

are detailed in Sections 6.1 to 6.3of the report. Final assessment of environmental impact from the activity is presented in

Section 7.0 of the report.

This Annual Return (Greencap Pty Ltd, 2018c) assesses compliance with conditions of the licence.


Status Compliant.

44. Condition The licensee must complete an Annual Return using the template in Appendix 4, and provide it to the administering

agency by the 30 September covering the period 1 August to 31 July, which relates to the preceding 12 month period.

How Refer to this report: Waste Discharge Licence 211 Annual Return 2018 – Bladin Point – Environmental Impact Monitoring

Program (Document Reference: L290-AH-REP-10800 (Greencap Pty Ltd, 2018c), which will be submitted to the NT EPA by

30/09/2018.

Evidence This report fulfils Condition 44 of WDL 211-4.

When (Date) The Annual Return to be submitted by 30/09/2018

Status Compliant.

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45. Action The administering agency may require the licensee to revise or amend and resubmit any Annual Return. Where the

administering agency requires the Annual Return to be resubmitted the date for resubmission will be specified and

will become a condition of this licence.

How Desktop Review.

Evidence The 2018 Annual Return for this Licence will be submitted to the NT EPA by 30/09/2018. If the Annual Return is required to be

resubmitted, it will be resubmitted to the NT EPA by the date specified.


Status Compliant.

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Waste Discharge Licence WDL 211 Annual Return 2018 39


8. REFERENCES

Australian and New Zealand Environment and Conservation Council and Agriculture and Resource

Management Council of Australia and New Zealand. (2000a). yAustralian and New Zealand

Guidelines for Fresh and Marine Water Quality. Canberra, ACT: Author.

Australian and New Zealand Standard 5667:4:1998 Water Quality Sampling – Guidance on sampling

from lakes, natural and man-made.


of rivers and streams.


from marine waters.

Charles Darwin University. (2011), Hydrodynamic Modelling of Darwin Harbour 2005-2010, Report 4.

Department of Natural Resources, Environment, the Arts and Sport (2010). Water Quality Objectives

for the Darwin Harbour Region – background document. Darwin, NT: Author.

Greencap Pty Ltd. (2017). Environmental Impact Monitoring Program. Revision 10. Darwin, NT.

Greencap Pty Ltd. (2018a). Waste Discharge Licence 211 Annual Monitoring Report 2018 – Bladin

Point – Environmental Impact Monitoring Program. Revision 0. Darwin, NT.

Greencap Pty Ltd. (2018b). Waste Discharge Licence 211 Annual Return 2018 – Bladin Point –

Environmental Impact Monitoring Program. Revision 0. Darwin, NT.

Greencap Pty Ltd (2018c). Annual Environmental Monitoring Report – Environmental Impact

Monitoring Program. Revision 1. Darwin NT.

INPEX Browse, Ltd. (2010). Ichthys Gas Field Development Project: Draft Environment Impact

Statement and the Supplement to the Draft Environmental Impact Statement. Perth, WA: Author.

JKC Australia LNG Pty Ltd. (2015a). Hydrotest Environment Management Plan. Revision E. Darwin,

NT (L290-AH-PLN-0023).

JKC Australia LNG Pty Ltd. (2015b). Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation. Darwin, NT (L290-AH-PLN-10231).

INPEX Operations Australia Pty Ltd (2016). Ichthys Onshore LNG Facilities - Construction

Environmental Management Plan (L092-AH-PLN-10001). Darwin, NT.

Northern Territory Environment Protection Authority (2015). Waste Discharge Licence (WDL211-1).




Northern Territory Environment Protection Authority. (2013). Guidelines on Mixing Zones. Version 1.2. Darwin, NT.

Waste Management and Pollution Control Act (NT).

Water Act (NT).

Water Act 2007 (Cth).

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APPENDIX ANT EPA Information Requests

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Chris Gamble

From: Shoanne Labowitch <[email protected]>Sent: Wednesday, 25 July 2018 4:52 PMTo: Waste NTEPA; Kresho ZicCc: Anthony BlackSubject: RE: WDL 211-4: Incident Notification - Unauthorised Discharge 06 July, 2018

Good afternoon Sally-anne, As per your email below, JKC hereby provides further information to clarify its actions and the notification sent to NT EPA on the 11th July, 2018, referred to as PRL7251. We have focussed the investigation report on Condition 18 – plant and equipment, and addressed Condition 38 reporting as follows: Condition 38.1: When the non-compliance was detected and by whom The leak from the MOF line was detected on the 6th July 2018 at 11:45 AM by JKC engineer Stephen Mellier. This was reported to NT EPA on the 11 July 2018. The reason for the delay in notification (5 days) was that the event was initially reported to our Client, INPEX on Friday 6th July, however there was some confusion as to the applicable approval under which the incident needed to be reported ( CEMP or WDL211). A decision was made on Tuesday that it was to be WDL 211-4 and JKC’s Lead Environmental Advisor responsible for the environmental assessment was sick that day. As a consequence, reporting to NT EPA occurred on Wednesday 11th July 2018. Controls have been put into place to prevent this reoccurring in that any WDL 211-4 equipment fault resulting in a discharge to Darwin Harbour will be reported under WDL 211-4 within 24 hours and in accordance with the licence conditions. Condition 38.2: The date and time of the non-compliance The MOF outfall line leak occurred during the day of the Friday 6th July 2018 and was detected at 11:45 AM. Condition 38.3: The actual and potential causes and contributing factors to the non-compliance The MOF discharge line coupling has come loose between the lay flat section and the solid pipe that goes down to the end of the MOF and the diffuser. The loose connection allowed for passive discharge of water into Darwin Harbour. Condition 38.4: The risk of environmental harm arising from the non-compliance JKC have calculated the volume released from the pipe and has determined it to be approximately 20KL of water that was charged in the section of lay flat pipe and that subsequently entered Darwin Harbour. A review of dewatering permits back to 16 June, 2018 have identified 4 firewater / potable water deluge permits, which totalled 274KL, and are associated with the water present in the pipework at the time of the non-compliance. As such, the water was considered to be uncontaminated potable water with an associated low risk when it was released into Darwin Harbour. Greencap were mobilised for precautionary sampling with analyses for the WDL 211-4 suite applicable to authorised discharge location DL1 [nutrients, metals and hydrocarbons] and the results are presented below. All other parameters did not exceed the water quality criteria. Environmental Investigation Results are available from the leak water and the 3 response sampling locations sampled 6th July 2018. The leak water from the MOF pipe was compared to the approved criteria for discharge via the regulating drain (DL1) and the harbour sites were compared to receiving environment water quality criteria as per WDL 211-4 in Table 1:

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Table 1: exceedance data comparison table Environmental Assessment of the results include:

- The leak water spill released from the MOF line contained exceedances of NOx, FRP, TSS and Zinc for authorised discharge Location DL1, and is a trigger of WDL 211-4 Condition 21.1.

- Only one analyte, TSS, was also exceeded in the receiving environment sampling. However, the concentration of TSS was lower in the leak water than in the receiving environment and therefore excludes the discharge as being the source of the TSS exceedance observed in the receiving environment.

- TP in the leak water did not exceed the approved criteria in WDL 211-4 and following 1:5 dilution that occurred as the discharge was released over the rock armour and into Darwin Harbour, would not be sufficient to be the source of the TP in the receiving environment.

- To put these results into context, JKC has prepared the control charts (e.g. section 6.4.3.3, of the ANZECC monitoring and reporting guidelines), which compares the receiving environment TSS and TP exceedances with the long term 80th percentile for the dry season reference site data collect from the EIMP. The reference data has been collected from the four EIMP reference sites and the upstream reference sites from the WDL 211-4 and the WDL 192-3 monitoring programs [see below figures].

- Based on the receiving environment results there were slight exceedances of the 80 percentile for NOx [1 location] and for TSS, TP and As [all 3 locations]. It is noted that the 80th percentile is calculated using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally, whereby the 80th percentile warns us when we are approaching the maximum seasonal values previously seen at the reference sites. Further review of the chart shows that the reference sites also exhibited NOx, TSS, TP and As concentrations above the 80th percentile value at times during the previous 2016/17/18 wet season and also during the current 2018 dry season.

- The spill of 20KL was of a limited duration and would have been substantially diluted by the diurnal tides that have occurred since the event.

- Therefore, the potential for environmental harm to the receiving environment receptors (water column, soft bottom benthic) associated with the discharge is negligible. The exceedances observed at the mixing zone monitoring locations are not believed to be attributable to the MOF spill event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters associated with Darwin Harbour seasonal cycles, with no associated risk of environmental harm.

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Figure 1- Receiving environment NOX exceedances versus the 80th percentile of reference locations

Figure 2- Receiving environment TP exceedances versus the 80th percentile of reference locations

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Figure 3- Receiving environment TSS exceedances versus the 80th percentile of reference locations

Figure 4- Receiving environment TSS exceedances versus the 80th percentile of reference locations Condition 38.5: The actions(s) that have or will be taken to mitigate any environmental harm arising from the non-compliance JKCs Environmental Monitoring Subcontractor have been mobilised to collect a sample from the leaked water and to undertake response sampling at 3 locations in proximity to where the escaped water entered Darwin Harbour and the non-compliance has been shown to have a negligible risk for environmental harm. The coupling has been realigned and leak has ceased with no ongoing unauthorised discharge occurring. Condition 38.6: Corrective actions that have or will be undertaken to ensure the non-compliance does not reoccur Reporting to NT EPA occurred on Wed 11th July 2018- 5 days after the event. Controls have been put into place to prevent this reoccurring in that any WDL 211-4 equipment fault resulting in a discharge to Darwin Harbour will be reported under WDL 211-4 automatically and within 24 hours. The coupling misalignment was caused partially - By degradation of sand bags that were in place to support and elevate the MOF outfall pipe at the junction of lay flat section and poly pipe section, which result in the pipe rolling over causing the cam lock to unlock. - No split pins were in place to prevent the lock from dislodging. The sand bags have been replaced and a cam lock fitted with a split pin as the key controls so this cannot reoccur.

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The team managing the MOF pumping have also included an additional control to undertake inspections of the line to check for physical issues like the above as part of their preventative maintenance operations. Condition 38.7: If no action was taken, why no action was taken Action was taken and is considered resolved. Condition 38.9: A date when an incident investigation or incident closure report, if requested by the administrating agency, will be submitted to the agency. The previous email from NT EPA outlines that JKC shall prepare a response by 25th July 2018. This communication provides the detailed environment investigation and assessment and fulfils the requirements of the closure report. We trust this provides a sufficient level of detail for the event to be closed out. If you have anything further, please contact the JKC Environment Manager Kresho Zic, on 08 8931 8986. Kind regards Shoanne Labowitch Government Approvals Manager Ichthys Project JKC Australia LNG Pty Ltd T300, 130 The Esplanade, Darwin, NT, 0800 PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected]

From: Sally-anne Orchard [mailto:[email protected]] On Behalf Of Waste NTEPA Sent: Wednesday, 11 July 2018 2:42 PM To: Kresho Zic <[email protected]> Cc: Anthony Black <[email protected]>; Shoanne Labowitch <[email protected]>; Waste NTEPA <[email protected]> Subject: RE: WDL 211-4: Incident Notification - Unauthorised Discharge 06 July, 2018 Hi Kresho, Thanks for your time on the phone today. As discussed, could you please provide an investigation report detailing information relevant to condition 38 of WDL211-4. In the investigation report, please also outline the results from your responsive sampling event including an environmental risk assessment. Please refer to trigger values within WDL211-4. Could you also please outline, with regard to condition 38.3 a response relative to condition 18 –equipment related to the matter. Please also outline in the investigation report, the reason for the delay in notification (5 days) and corrective actions that will be undertaken to ensure significant delays in non-compliance notification reporting do not reoccur. Please provide the report within 10 business days, by 25 July 2018. For your records, the non-compliance notification has been recorded in our database as PRL7251. Regards,

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Sally-Anne Sally-Anne Orchard | Environmental Officer I Environmental Authorisations Environment Division | Department of Environment and Natural Resources p...(08) 8924 4028I f... (08) 8924 4053 e [email protected] I www.ntepa.nt.gov.au Providing services for the Northern Territory Environment Protection Authority

Level 1, Arnhemica House, 16 Parap Road, Parap NT 0820 GPO Box 3675, Darwin NT 0801 Our Vision: Creating a public sector that provides the highest quality service to Territorians Our Values: Commitment to Service | Ethical Practice | Respect | Accountability | Impartiality | Diversity

Please consider the environment before printing this email. Use or transmittal of the information in this email other than for authorised NT Government business purposes may constitute misconduct under the NT Public Sector Code of Conduct and could potentially be an offence under the NT Criminal Code. The information contained in this message and any attachments may be subject to legal privilege, public interest or legal profession privilege. If you are not the intended recipient, any use, disclosure or copying of this message or any attachments is unauthorised. If you have received this document in error, please advise the sender. No representation or warranty is given that attached files are free from viruses or other defects. The recipient assumes all responsibility for any loss or damage resulting directly or indirectly from the use of any attached files.

From: Shoanne Labowitch [mailto:[email protected]] Sent: Wednesday, 11 July 2018 11:31 AM To: Waste NTEPA Cc: Anthony Black; Kresho Zic Subject: WDL 211-4: Incident Notification - Unauthorised Discharge 06 July, 2018 Good morning, In accordance with WDL 211-4 Condition 36 to Condition 38, JKC Australia LNG Pty Ltd (JKC) hereby informs NT EPA concerning a non-compliance with WDL 211-4 Condition 19 and Condition 21, regarding the passive discharge of potable water from a loose pipe coupling associated with the equipment used to conduct the MOF discharge activity approved under WDL 211-4. The non-compliance occurred on Friday 06 July, 2018. Information available is as follows: The MOF discharge line coupling has come loose between the lay flat section and the solid pipe that goes down to the end of the MOF and the diffuser. The loose connection allowed for passive discharge of water into Darwin Harbour:

• JKC have calculated the volume released from the pipe and has determined it to be approximately 20KL of water that was charged in the section of lay flat pipe and that subsequently entered Darwin Harbour.

• There was not any active discharge under WDL 211-4 occurring at the time of the event. • A review of recent dewatering permits back to 16 June, 2018 have identified 4 firewater / potable water

deluge permits, which totalled 274KL, and are associated with the water present in the pipework at the time of the non-compliance,

Results are available from 03 June, 2018 for samples collected from the most recent sampling event for the characterisation of water contained within the C600 holding basin. When the data collected is compared with the Receiving Environment Water Quality Monitoring Trigger Values, a number of exceedances were observed that are applicable to authorised discharge location, DL1 (Regulating Reservoir), and are described below: - Ammonia (57 µg/L) – TV 47 µg/L - Zinc (28 µg/L) – TV 23.9 µg/L

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• JKCs Environmental Monitoring Subcontractor have been mobilised to collect a sample from the leaked

water and to undertake response sampling at 3 locations in proximity to where the escaped water entered Darwin Harbour, the results from this sampling are due next week,

• The coupling has been realigned and leak has ceased with no ongoing unauthorised discharge occurring, • There was a 2.94m tidal variance for the next cycle on the day of the non-compliance – outgoing.

For further information, please contact the JKC Environmental Manager Kresho Zic, on 8931 8986 Kind regards Shoanne Labowitch Government Approvals Advisor Ichthys Project JKC Australia LNG Pty Ltd T300, 130 The Esplanade, Darwin, NT, 0800 PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected] This e-mail, including any attached files, may contain confidential and privileged information for the sole use of the intended recipient. Any review, use, distribution, or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive information for the intended recipient), please contact the sender by reply e-mail and delete all copies of this message.

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Chris Gamble

From: Shoanne Labowitch <[email protected]>Sent: Monday, 27 August 2018 4:21 PMTo: Waste NTEPA; Kresho ZicCc: Anthony BlackSubject: RE: WDL 211-4 Notification of Non-Compliance with Trigger Values for NOx - 19

July 2018

Good afternoon Sally-anne, I will respond on Kresho’s behalf, Yes, there are two different aspects to note concerning the observed exceedance of Oxides of Nitrogen: - The first aspect is the heterogeneity of the sample when comparing the reportable exceedance with the greater 80th percentile dataset collected for the EIMP. For the EIMP data, elevated NOx and nutrient values in the harbour are commonly recorded. This is a relatively common occurrence and is sometimes observed in the samples collected from the mixing zone locations, as was the case on this occasion. - The second aspect is that the physico-chemical data (i.e. EC and turbidity etc.) measured at the mixing zone sampling locations were observed to be very stable during the sampling event. This suggests that any influence from a freshwater plume discharged from the MOF during the discharge event has not occurred, and that the diffuser is working as per the design and resulting in sufficient dilution of the discharged water. Furthermore, there were no observed sheens, scums, plumes etc. noted during the field observations that were taken during the sampling event. Kind regards Shoanne Labowitch Government Approvals Manager Ichthys Project JKC Australia LNG Pty Ltd T300, 130 The Esplanade, Darwin, NT, 0800 PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected]

From: Sally-anne Orchard [mailto:[email protected]] On Behalf Of Waste NTEPA Sent: Wednesday, 22 August 2018 10:03 AM To: Kresho Zic <[email protected]> Cc: Shoanne Labowitch <[email protected]>; Anthony Black <[email protected]> Subject: RE: WDL 211-4 Notification of Non-Compliance with Trigger Values for NOx - 19 July 2018 Hi Kresho, I am hoping to enquire about the non-compliance further. In relation to point 6 below, were there any field observations observed or significant variations in physico-chemical parameters measured during the sample event, in the sample matrix that would further support this conclusion? I note that in terms of seasonal cycles, NOx is typically elevated in the wet season. Regards, Sally-Anne Orchard

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Environmental Officer Environmental Authorisations Department of Environment and Natural Resources Northern Territory Government Providing services for the

www.ntepa.nt.gov.au Level 1, Arnhemica House, 16 Parap Road, Parap NT 0820 GPO Box 3675, Darwin NT 0801 P: 8924 4028 E: [email protected] W: www.denr.nt.gov.au

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Use or transmittal of the information in this email other than for authorised NT Government business purposes may constitute misconduct under the NT Public Sector Code of Conduct and could potentially be an offence under the NT Criminal Code. The information in this e-mail is intended solely for the addressee named. It may contain legally privileged or confidential information that is subject to copyright. If you are not the intended recipient you must not use, disclose copy or distribute this communication. If you have received this message in error, please delete the e-mail and notify the sender. No representation is made that this e-mail is free of viruses. Virus scanning is recommended and is the responsibility of the recipient

From: Shoanne Labowitch <[email protected]> Sent: Tuesday, 21 August 2018 9:35 AM To: Waste NTEPA <[email protected]> Cc: Anthony Black <[email protected]>; Kresho Zic <[email protected]> Subject: WDL 211-4 Notification of Non-Compliance with Trigger Values for NOx - 19 July 2018 Good afternoon, In accordance with the reporting requirements under WDL 211-4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a mixing zone median exceedance of the trigger value for Oxides of Nitrogen (NOx), which was more than double the 20 µg/L trigger value, and was not also present at the upstream reference site, as per Appendix 3 of WDL 211-4. The median exceedance was detected during surface water monitoring activities undertaken on 19th July, 2018. Monitoring was associated with the discharge of AOC waters from the C600 holding basin. JKC received the sampling results information yesterday, 20th August, 2017, from its Environmental Monitoring Subcontractor following compilation of the dataset and completion of quality assurance reporting. JKC has requested Subcontractor efforts to ensure sampling results are provided in a more expedient manner going forward. Details of the exceedance detected during the surface water monitoring sampling event are outlined below:

1. A median exceedance of 52 µg/L for Oxides of Nitrogen was detected at the MOF mixing zone for authorised discharge location DL2, as defined in Table 3 of WDL 211-4. The exceedance was not detected at the upstream reference site, with a value of 10 µg/L . It was however detected at the downstream monitoring site with a value of 48 µg/L .

2. The surface water sampling was undertaken on 19th July, 2018 at 11:42AM, during an outgoing tidal phase

with a 4.49 m amplitude.

3. End of pipe sampling was undertaken on 17th July, 2018, 2 days prior to discharge via the MOF outfall. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (Document No. L290-AH-

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PLN-10231). The sampling returned an Oxides of Nitrogen value of 710 µg/L, which following dilution of 80 fold, is not sufficient to result in the observed median exceedance at the mixing zone monitoring locations.

4. This sampling event forms one of a series of monitoring events for the discharge which ran from 17th July

through to the 31st July 2018. There were no other median exceedances of NOx in the discharge prior to and after the reportable event, which demonstrates that the exceedance is not related to the discharge event.

5. The potential for the discharged water to be the source of the exceedance recorded at the mixing zone

monitoring location is therefore considered to be Low.

6. The median exceedance observed at the monitoring locations is not believed to be attributable to the MOF discharge event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters with no associated risk of environmental harm.

The NOx mixing zone exceedance data exceeds the 80th percentile for the reference sites. The exceedance of the 80th percentile is a trigger for further investigation.

Further investigation Construction water sampling was undertaken prior to discharge via the MOF outfall, with the most recent sample collected on the 17th July, 2018. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (Document No. L290-AH-PLN-10231). The sampling returned an Oxides of Nitrogen value of 710 µg/L, which following dilution of 80 fold, is not sufficient to result in the observed median exceedance at the mixing zone monitoring locations. Further, this sampling event forms one of a series of monitoring events for the discharge which ran from 17th July through to 31st July 2018. There were no other median exceedances of NOx in the discharge prior to and after the reportable event, which demonstrates that the exceedance is not related to the discharge

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event. Therefore, the potential for the NOx exceedance to be attributed to the discharge, and potential for environmental harm to the receiving environment receptors (water column, soft bottom benthic) associated with the discharge is negligible.

It is noted that the 80th percentile is calculated using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally, whereby the 80th percentile warns us when we are approaching the maximum seasonal values previously seen at the reference sites. Further review of the chart shows that the reference sites also exhibited NOx concentrations above the 80th percentile value at times during the previous 2016/17 wet season and also during the current 2017/18 wet season. The NOx exceedances detected during sampling of the mixing zone are considered to represent seasonal harbour based influences and were not associated with the WDL211-4 discharges. The median exceedance observed at the mixing zone monitoring locations is not believed to be attributable to the MOF discharge event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters associated with Darwin Harbour seasonal cycles, with no associated risk of environmental harm. For further information, please contact the JKC Environment Manager Kresho Zic, on 08 8931 8986. Kind regards Shoanne Labowitch Government Approvals Manager Ichthys Project JKC Australia LNG Pty Ltd T300, 130 The Esplanade, Darwin, NT, 0800 PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected] This e-mail, including any attached files, may contain confidential and privileged information for the sole use of the intended recipient. Any review, use, distribution, or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive information for the intended recipient), please contact the sender by reply e-mail and delete all copies of this message.

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APPENDIX BCommunity Relations Plan

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COMPANY DOC. No. L290-AB-PLN-0150 REV.

JKC DOC. No. S-0290-1192-0001 1

COMPANY CONTRACT No. 800224 Review Class. 1

JGC JOB No. 0-6037-21 KBR JOB No. F034 CHIYODA JOB No. 11051 SHEET 1 OF 33

REV. DATE ISSUE PURPOSE PREPARED CHECKED APPROVED

A 05-Jul-11 IFA L. Parsons I. McAteer I. McAteer

B 18-Nov-11 IFA B. Franklin I. McAteer I. McAteer

0 28-Mar-12 IFC A. Kelly B. Franklin B. Franklin

1 25-Jul-13 IFC A. Kelly B. Franklin B. Franklin

FORM EPC-1 4

INPEX Operations Australia Pty Ltd

ICHTHYS ONSHORE LNG FACILITIES

COMMUNITY RELATIONS PLAN

INDRA31-JUL-2013INDRA28-SEP-2018


INPEX Operations Australia Pty Ltd COMPANY Doc. No. L290-AB-PLN-0150 ICHTHYS ONSHORE LNG FACILITIES JKC Doc. No. S-0290-1192-0001 Rev.1 Community Relations Plan Sheet No. 2 of 33

Contents

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

1.1 Scope ................................................................................................................ 3 1.2 Definitions ......................................................................................................... 3 1.3 Applicable documents ....................................................................................... 4 1.4 Abbreviations .................................................................................................... 4

2. OBJECTIVES ................................................................................................... 6

3. ORGANISATION AND STAKEHOLDERS ....................................................... 7

3.1 Key Stakeholders .............................................................................................. 7 3.2 Contractor Community Relations Team ............................................................ 7 3.3 Roles and responsibilities................................................................................ 10

4. ENGAGEMENT MODEL ................................................................................. 11

4.1 Top-down engagement model during construction .......................................... 12 4.2 Regular, open and personal contact ................................................................ 12

5. OVERVIEW OF COMMUNITIES AND KEY STAKEHOLDERS ..................... 12

5.1 Key stakeholder groups by external affairs function ........................................ 12 5.2 Communities in areas of construction and operation ....................................... 13

6. COMMUNITY RELATIONS PROCEDURES .................................................. 14

6.1 General ........................................................................................................... 14 6.2 Aboriginal and Torres Strait Islander (ATSI) relations ...................................... 14 6.3 Media protocols ............................................................................................... 14 6.4 Government relations ...................................................................................... 15 6.5 Complaints management ................................................................................. 15 6.6 Crisis management ......................................................................................... 15 6.7 Howard Springs Accommodation Village ........................................................ 15 6.8 Identifying key community issues .................................................................... 15 6.9 Communication channels ................................................................................ 17 6.10 Promoting the joint venture .............................................................................. 19 6.11 Community grievance management procedure ............................................... 20 6.12 Public risk and incident communications ......................................................... 20

6.13 Lessons learned………………………………………………………………………5

7. CONTRACTOR ENGAGEMENT .................................................................... 21

7.1 Community Relations Working Group ............................................................. 21 7.2 Public communication protocols ...................................................................... 21

8. SUBCONTRACTOR ENGAGEMENT ............................................................. 22

APPENDIX A JKC JV ADVICE TO SUBCONTRACTORS: PART 1 ........................ 23 APPENDIX B JKC JV ADVICE TO SUBCONTRACTORS: PART 2 ........................ 26 APPENDIX C JKC JV ADVICE TO SUBCONTRACTORS: PART 3 ........................ 29




1. INTRODUCTION

1.1 Scope

This Community Relations Plan describes the management controls and processes Contractor will have in place to manage Community Relations during the execution/construction and commissioning phase of the Ichthys Gas Field Development Project. Contractor will work closely with Company to ensure community and stakeholder communications protocols are followed and the community engagement approach is consistent across Company, Contractor and Subcontractor personnel. As a consequence, this Plan is aligned to, and builds upon, the Company Plan in those areas under the direct control of Contractor.

The construction phase will represent the height of activity for the Project and will be the phase most likely to have a direct impact on the community, through issues such as:

housing and rental market pressure

local infrastructure (roads, services)

labour market pressure

Australian content and jobs

environmental impacts

public safety.

Effective community engagement during this critical period is essential to enhance Company and Contractor reputation. Engagement also helps achieve mutually beneficial outcomes for specific aspects of the Project.

Implementation of this Plan will assist in achieving both the regulatory and social licences to operate, while delivering on the Project schedule and protecting and enhancing the reputation of Company and Contractor.

This plan outlines:

The management framework which will govern the Project’s community engagement program during construction

The range of community stakeholders requiring engagement

The processes for identifying and managing issues of potential interest or concern to the community

communication methods for engaging with community

methods Company will use for measuring the effectiveness of Contractor’s community engagement program

how Contractor will coordinate activities to ensure consistency and clear lines of responsibility in community relations.

This Plan is informed by other existing management plans and will be supported by detailed existing and proposed detailed construction communication action plans which will be developed for specific activities in line with Project timelines.

The timeframe of this plan includes pre-mobilisation, construction, and commissioning under the direct control of Contractor.

1.2 Definitions

Company INPEX Operations Australia Pty Ltd acting as agent for Ichthys LNG Pty Ltd




Contractor JKC Australia LNG Pty Ltd—the Joint Venture between JGC Corporation, KBR (Kellogg Brown & Root Pty Ltd) and Chiyoda Corporation

Ichthys Project Ichthys Gas Field Development Project

Site Location where the plant is to be constructed and the vicinity thereof

Subcontractor Any company to whom Contractor has subcontracted any part of the works

Worksite Any location where work for the site is carried out

1.3 Applicable documents

1.3.1 Contractor documents

S-0290-11N0-0001: The Aboriginal and Torres Straight Islander Affairs Plan

S-0290-1190-0002: Howard Springs Accommodation Village – Communications Action Plan

S-0290-1190-0003: Road Transport – Communications Action Plan

S-0290-11Z0-3001: Howard Springs Accommodation Village Simultaneous Operations Phase – Communications Action Plan

1.3.2 Company documents

C025-AG-PLN-0026: External Stakeholder Engagement Plan

C025-AG-POL-0002: Community Grievance Management Procedure

C025-AG-POL-0002: Transport Management Communications Plan—Roads

C025-AG-POL-0002: Transport Management Communications Plan—Marine

1.4 Abbreviations

ALARP as low as reasonably practicable

ATSI Aboriginal and Torres Strait Islander

CLO Community Liaison Officer

CRC Community Relations Coordinator

MCO

CRM

Media & Communications Officer

Community Relations Manager

CRWG Community Relations Working Group

EAM External Affairs Manager

EIS Environmental Impact Statement

EPC Engineering, Procurement and Construction

HSES health, safety, environment and security

KBR Kellogg Brown & Root Pty Ltd

MHF Major Hazard Facility




NGO Non Government Organisation

PPE Personal Protective Equipment

RTMP Road Transport Management Plan

SRM Stakeholder Relationship Management




2. OBJECTIVES

The key objectives of this Plan are to:

provide an outline of the management framework and guidelines which will govern the Contractor community engagement program during construction

assist with the identification and management of issues of interest to community

support the achievement of government approvals to meet the Project schedule

plan and implement communication plans

identify the range of materials for release to external stakeholders in a timely manner, consistent with Company and Contractor requirements

ensure regular and consistent messaging to the community.

Achievement of these objectives will help protect and enhance the reputation of Company, Contractor and Subcontractor during construction.




3. ORGANISATION AND STAKEHOLDERS

3.1 Key Stakeholders

External stakeholders in the project include:

elected government representatives

government staff

non-government organisations (NGOs)

media organisations

general community.

Company has developed a External Stakeholder Engagement Plan (C025-AG-PLN-0026), along with

other associated management plans detailing the protocols for communicating with stakeholders for a

wide range of issues. Contractor will comply with the requirements of these plans. Subcontractors

must also comply through input into Subcontractor Community Relations Plans. Contractor has

provided documented advice to Subcontractors in relation to community engagement, communications

protocols and branding policies. In conjunction with Company and Subcontractors, Contractor will manage and implement community and stakeholder plans with a team of professional Community Relations personnel which includes:

Community Relations Manager

Media & Communications Officer

Two Community Relations Coordinators.

3.2 Contractor Community Relations Team

The Contractor Community Relations team is made up of a Community Relations Manager (CRM), a Media & Communications Officer and two Community Relations Coordinators. This team will facilitate all communications with support and guidance from the Contractor External Affairs Manager (EAM).

The CRM reports directly to the EAM. The CRM and MCO will be located in the Darwin Contractor office, while the CRC’s during the construction phase.

The CRM will guide the Subcontractor community relations personnel, and will be responsible for the day-to-day community relations and communications functions for all activities associated with the Contractor construction impacts across the community. This will include the two significant locations: Howard Springs Accommodation Village and the Blaydin Point Ichthys LNG Facility.

The CRM is Contractor’s single point of contact for all community relations and is responsible for the following:

provision of Contractor project information to Company External Affairs and Public Affairs personnel

participation in regular meetings with Company to discuss community feedback and other community relations issues, in particular the coordinating body—the Community Relations Working Group (CRWG)

assisting Company with the resolution of community complaints and public protests in conjunction with the Company Grievance Management Procedure and with oversight from the Community Relations Working Group (CRWG)

directing public feedback to relevant Company and Subcontractor personnel INDRA31-JUL-2013INDRA28-SEP-2018



scheduling, attending and assisting with site tours, as required by Company, Contractor and Subcontractor

identifying, coordinating and managing community events on behalf of Contractor

identifying, coordinating and managing community sponsorship opportunities on behalf of Company and Contractor

communicating Project activities in regular newspaper advertisements and in other forums, as requested by Company and Contractor

other community engagement tasks, as requested by Company and Contractor

formal and informal monitoring and recording of site work, scheduling, logistics, milestones and other project activities for community information purposes

generating and maintaining periodic photographic records of construction progress and key milestones for internal and external use, and in accordance with agreed protocols

liaising with the HSES Manager for the development, implementation and evaluation of community management procedures during crisis situations.

Reporting to the CRM are two Community Relations Coordinators who will be located in the Darwin Contractor office during the construction phase. Their role is to:

provide assistance to the CRM to implement the Community Relations Plan and supplementary plans

to provide advice to the CRM and other Project personnel regarding community relations issues

research, design and generate communications materials for target audiences as directed by the CRM

organise and facilitate community events and Contractor milestone functions

manage the 1300 724 795 community feedback freecall number on a rostered basis to ensure the timely and accurate answering, logging, response, and/or potential escalation of community enquiries and complaints in accordance with the Company Community Grievance Management Procedure

support other Contractor function areas where required.

The Contractor external affairs organisation chart is provided in

Figure 3.1

External Affairs Manager INDRA31-JUL-2013INDRA28-SEP-2018



Figure 3.1: Contractor external affairs organisation chart




3.3 Roles and responsibilities

3.3.1 Construction Site Manager

The Construction Site Manager may be required to attend and/or lead site tours for dignitaries and Company representatives, as requested by Company. Site visits for Contractor representatives may also be conducted by the Construction Site Manager, in the event that the Project Director is unavailable.

The Construction Site Manager will assist and support the CRM in monitoring the works and providing advice on proposed project activities, or issues of community interest or concern.

3.3.2 Project officers

Project officers in all locations are required to adhere to the community relations principles and communications protocols outlined in this Plan. No Contractor personnel are authorised to have any contact with stakeholders unless specifically granted by Company in writing.

Contractor may request Company permission to publish Project information (i.e. for newsletters with distribution outside the Project team) through the Contractor Community Relations Coordinator in accordance with the Contractor’s Advice for Subcontractors Part 3 (Protocols).

3.3.3 Package Manager

Package Managers will assist and support the CRM and CRCs in provision of timely and accurate information, monitoring of the works and advising of other project activities.

3.3.4 Contractor and Subcontractor personnel

No Contractor and Subcontractor personnel are authorised to have any contact with stakeholders unless otherwise specifically granted by Company in writing, in accordance to the Contractor’s Advice for Subcontractors Part 1 (Engagement).

3.3.5 Communications

The CRM and EAM work together with Company Public Affairs and External Affairs teams in Perth and Darwin to manage stakeholder relations during the construction execution phase. All Contractor and Subcontractor communications to stakeholders are guided by the management plans listed in Section 1.3. The majority of pro-active stakeholder engagement activity as well as reactive escalated grievances will be managed through the CRWG, while daily management of routine enquiries will be managed at the point of contact by the Contractor community relations team.




4. ENGAGEMENT MODEL

Since the announcement in 2008 that Darwin would be the location for the Ichthys LNG plant and associated onshore facilities, Company has undertaken extensive consultation with community (and other) stakeholders in Darwin and in the wider Australian context. The overarching objectives of this engagement have been to:

protect and enhance the reputation of Company, and of the Ichthys Project

provide a framework of positive engagement to facilitate government approvals associated with the Project.

The top-down engagement model typically adopted by Company, as Operator of the Project, for major disclosures of information to government and the community has resulted in positive outcomes for Company and the Project across all functional areas. This model is shown in Figure 4.1.

The engagement model is summarised as “top-down”, by which it is meant that significant public announcements are typically advised to the Head of Government first. Under this model, the information is then communicated down to key elected representatives (relevant ministers, Members of Parliament, local government representatives) and then to the broader community.

Messages are communicated to these stakeholder groups using various communication channels.

Figure 4.1: Top-Down stakeholder engagement model (Northern Territory)

Note: Certain Project disclosures will not follow this model; for example, disclosures that relate strictly to approvals processes which will originate at the working level of government.

Company personnel across the key functional areas of Darwin Office, Government Affairs, Public Affairs, Environment, Government Approvals and Contracts have regular contact with departmental counterparts on an ongoing basis. This occurs both in formal meetings, such as the regular High Level Group meetings of NT Government departmental heads with the Director Corporate Co-ordination and GM Darwin, and in meetings at the working level to maintain relationships and generate bilateral understanding pending approvals requirements.




Departmental personnel are, therefore, likely to be communicating upwards to their ministers in some cases.

This Plan follows the top-down model that has been developed and is considered to have functioned successfully to date.

4.1 Top-down engagement model during construction

While major announcements are likely to continue to be delivered to key stakeholders and the community using the top-down model described above, much of the day-to-day information required to be communicated to the community during the construction phase will be undertaken by Contractor direct to the community.

Information of this nature particularly relates to issues of public safety associated with construction activities that have the potential to highly impact the community, such as activities within the Howard Springs Accommodation Village site and rock transport to Blaydin Point and East Arm Wharf from the quarries

During the construction phase, Contractor will work in conjunction with Company in coordinating community communication activities to ensure communications are consistent with the expectations of Company.

4.2 Regular, open and personal contact

While Contractor will manage and document day-to-day community interaction associated with construction activities, regular, open and personal contact with key stakeholders will be managed by the Company according to the top-down engagement model. Contractor will build on the level of trust and two-way communication process during a transitional phase into the construction period where Company will monitor, but not continue to lead, the broader community engagement activities.

5. OVERVIEW OF COMMUNITIES AND KEY STAKEHOLDERS

5.1 Key stakeholder groups by external affairs function

5.1.1 Community

The Project’s key community stakeholders include the following:

local government authorities

businesses and business associations

non-government organisations

media

local residents in our areas of operation (listed below)

sponsorship partners.

Contractor will be provided with access to, and will refer to the Company Stakeholder Database for full details of all stakeholders.

5.1.2 Government

Company will continue to instigate and manage engagement with Federal, Territory and State government stakeholders, with support from Contractor where requested. Contractor engagement will not include Federal communications unless necessary.

5.1.3 Aboriginal and Torres Strait Islander peoples

Targeted engagement with ATSI stakeholders is referred to separately in the following plans:

Ichthys Project Aboriginal and Torres Strait Islander Business Engagement Plan (C015-AG-PLN-0003) INDRA

31-JUL-2013INDRA28-SEP-2018



JKC Aboriginal and Torres Strait Islander Affairs Plan (S-0290-11NO-0001).

5.2 Communities in areas of construction and operation

Contractor will concentrate its community engagement in the following key areas during construction.

5.2.1 Darwin

The proposed onshore gas processing facilities for the Project will be located 13 km from Darwin’s central business district (CBD). The Project’s impact on Darwin CBD is expected to be largely economic, in terms of upward pressure on rents and decreased availability of apartments and commercial premises. Small businesses and the entertainment precinct along Mitchell Street will benefit from increased custom. This may also lead to upward pressure on prices.

5.2.2 Palmerston

The proposed onshore gas processing facilities will be located 8 km from the centre of Palmerston. Palmerston is also close to the location of the construction workforce accommodation facility—the Howard Springs Accommodation Village. It is proposed to use suburban roads within Palmerston for the workforce bus route to and from Blaydin Point and for materials transport to the Village and Blaydin Point.

5.2.3 Howard Springs

Howard Springs is on the fringe of Darwin's expanding residential areas south along Stuart Highway. It is the location of the construction workforce accommodation village—Howard Springs Accommodation Village. Howard Springs is characterised by large “rural” blocks (1–2 hectares) in contrast to the high-density village design.




6. COMMUNITY RELATIONS PROCEDURES

6.1 General

The CRM and/or EAM will participate in public forums, government meetings and other official events as Contractor representative, at the request of Company. The CRCs and other Contractor representatives will also be involved in community events and stakeholder liaison, as required.

Where community issues are not able to be resolved in the first instance by Contractor via the community feedback mechanisms, Company and Contractor will discuss and resolve community issues through the Community Relations Working Group. Contractor will document all community interaction in a customised community consultation database that is similar to the Company system.

Contractor, with the approval of Company, will organise community events throughout the execution phase of the project. The CRM will submit event proposal(s) to Company for consideration, as required. Contractor and Company will evaluate, discuss and agree resources required for community events and stakeholder liaison on a case-by-case basis.

Contractor will engage the services of a local professional photographer to take images of regular construction progress and milestones for Contractor and Company purposes.

6.2 Aboriginal and Torres Strait Islander (ATSI) relations

The Aboriginal and Torres Strait Islander Affairs Plan (S-0290-11N0-0001) details the stakeholder engagement and business engagement strategies for these specific stakeholder group(s). Contractor ATSI community relations is managed by the Cultural Affairs Supervisor with support from the Community Relations team. The CRM will work together with the Supervisor to ensure information communicated to all stakeholders is consistent with Contractor and Company expectations.

6.3 Media protocols

Only Company-authorised personnel are permitted to make public statements on Project issues, unless otherwise agreed by Company External Affairs and Darwin General Manager. Contractor and Subcontractors are not permitted to comment about the Project to the media and will refer all enquiries to Company representatives.

Company will arrange media training for Contractor personnel where required.

Contractor Advice to Subcontractors Part 3 (Protocols) outlines the Company and Contractor agreed method of publicly releasing all types of communication.

Contractor will advertise project activities in the local NT News newspaper each Saturday, as well as the respective community newspapers where appropriate. The advertisement will appear in the Contractor standard template and will include information about the following project impacts on the community:

major traffic movements and disruptions

major vessel movements and disruptions

other project activities likely to impact stakeholders

Project milestones and achievements

community events

community feedback opportunities

where to find additional information about the Project.

This information will also be provided to Company for inclusion in other Project communications.




6.4 Government relations

All Contractor and Subcontractor communications with elected Government Representatives is to be carried out through the Contractor Community Relations Managers, or delegate, to Company representatives, unless otherwise approved by Company in writing, or by direction through the Community Relations Working Group.

Likewise, all Contractor and Subcontractor communications to government personnel will be made through the Community Relations Manager to Company representatives, unless otherwise directed by Company.

Contractor and Subcontractor regulatory compliance personnel will be required to liaise directly with government personnel to organise approvals and licences to undertake portions of work. Contractor will seek formal approval from Company to directly contact the relevant government agencies upon commencement of the execution phase, and will document all instances of interaction with these stakeholders.

6.5 Complaints management

All community feedback will be managed on a case-by-case basis.

The majority of feedback will be managed as close to the point of contact as possible and will be documented in the stakeholder consultation management database.

Where feedback cannot be resolved in the first instance, it will be managed in accordance with the Company Community Grievance Procedure (doc number) aligned with the Community Relations Working Group’s (CRWG’s) Terms of Reference.

The CRWG will regularly meet to discuss issues raised by stakeholders. Contractor will assist with the resolution of complaints, as required, and will agree on the appropriate actions required to communicate the resolution to the community member.

6.6 Crisis management

Contractor will assist Company with the management of stakeholder crises, as required.

The CRM will work together with the HSES Manager to develop specific community crisis management procedures for the site, including:

civil unrest at site boundaries, Contractor office(s) and Accommodation Village

protestor management.

6.7 Howard Springs Accommodation Village

The Howard Springs Accommodation Village Subcontractor will appoint a Community Relations Coordinator who will be guided by the CRM and will be responsible for the resolution and communications of community relations issues regarding the construction of the Accommodation Village.

When occupation commences the Howard Springs Accommodation Village Operator will have a Village Liaison Officer to manage internal village community relations issues and report to the CRM for issues relating to interface management between the Village and the broader community.

The Coordinator and Officer will attend regular meetings between Contractor and Company to discuss community relations matters, resolve complaints and facilitate project information to the relevant stakeholders.

6.8 Identifying key community issues

6.8.1 Identified issues

Extensive community engagement and formal consultation has identified the following key issues as areas of concern for the wider Darwin community:




housing and rental market pressure

local infrastructure (roads, services) pressure

increased harbour traffic

labour market pressure

local content, jobs and training opportunities

environmental impacts

public safety

social impacts such as workforce integration and impact on health services

recreational fishing impacts, including creek access adjacent to Blaydin Point.

Issues of concern to the community are captured in an Issues Register managed by Company External Affairs.

Issues relating specifically to ATSI peoples will be detailed in the Contractor Aboriginal and Torres Strait Islander Affairs Plan (S-0290-11N0-0001).

6.8.2 Prioritising issues

Issues of interest to community stakeholders generally have two broad impacts:

reputation

project schedule/cost.

Reputation issues may or may not have a direct impact on the Project schedule. Community issues that do have the potential to impact both the Project schedule and the reputation of Company and Contractor are considered a priority. The level of priority and associated impacts are outlined in Table 6.1

Table 6.1: Issues priority matrix

Priority Level Impact on External Reputation Impact on Project Schedule/Costs Yes No Likely Unlikely

No Action (low) x x

Level 1 x x

Level 2 x x

Level 3 (high) x x

Issues register

An issues register will be maintained within the broader stakeholder consultation management system by the EAM and CRM to document key areas of community and media interest to Project stakeholders. The register is maintained and updated after milestone community engagement events and includes the issues raised by stakeholders, the Company response, and details of briefings with stakeholders.

Stakeholder database

Contractor maintains a comprehensive database of community stakeholders across all jurisdictions. The stakeholder database is reviewed regularly to ensure the data is valid, particularly ahead of key milestone events. The database includes the Issues Register where all areas of concern and interest can be tracked over time, evaluated and fed back into planning future activities and mitigation measures.




Community grievance management procedure

The Company Community Grievance Management Procedure provides a standard process for responding to and resolving grievances raised by the community, which assists with the identification and management of issues. The procedure includes how Company will work with Contractor to identify and resolve issues as early as possible to reduce the potential for community concerns to escalate to the media or to the political level.

6.9 Communication channels

The key methods and tools of communication used to engage with the community are set out below:

6.9.1 Communication plans and Q&As

Communication plans are prepared for specific Project milestones and activities. Q&As and key messages are prepared for a wide range of activities and issues. A general Project Q&A is maintained by Company and Contractor and used to guide all communications with community stakeholders. This is aligned to similar Company documents.

6.9.2 Briefings (formal and informal)

Both formal (minuted) and informal briefings (in person or by phone) are used as regular forms of engagement with community stakeholders. Details of formal stakeholder briefings are recorded in minutes of the meeting and distributed to relevant staff. These are also entered into the database. Issues of community concern may also be detailed within the issues register.

6.9.3 Website and feedback numbers

Company will oversee an Ichthys Project web site which will be populated by Company and Contractor. Company will continue to manage an 1800 community general enquiry phone number. During the construction phase Contractor will also manage a community feedback number (1300 724 795), specifically for issues regarding construction impacts.

6.9.4 Media

Will be managed in liaison between the Contractor Media & Communications Officer and the Company Communications Manager. Media releases are prepared for Project milestones and other events or issues. These are distributed to key media contacts and uploaded to the Company and Ichthys Project web sites as appropriate. Media interviews may be considered for Company and Contactor personnel who have received media training, as required. The releases must be generated, approved and issued following the agreed public communications protocols.

6.9.5 Fact sheets

Fact sheets are developed for particular Project issues and activities. These can be distributed at community forums and events, uploaded to the Company and/or Ichthys Project web sites, or distributed in person at briefings. All fact sheets must be generated, approved and distributed as per the agreed public communications protocols.

6.9.6 Electronic newsletter

Contractor, in conjunction with Company, will produce an electronic newsletter in html format. This will be distributed to subscribers registered through the Ichthys Project web site. The newsletter will provide periodic Project updates and will communicate information regarding particular Project activities. All content must be generated, approved and included as per the agreed communications protocols.

6.9.7 Advertising




Advertising can help communicate key messages to the community, particularly during key Project milestones such as the completion of large packages of work. The majority of advertising will be centred around regular Contractor Community Bulletins and recruitment. Articles will be generated for specific interest publications where content has been approved as per the agreed communications protocols to support community awareness activities for targeted audiences and reputation management.

6.9.8 Community forums

Contractor community forums will take place at the direction of Company as a means of direct consultation with the community during key construction activities to determine the understanding of issues of importance to the community.

6.9.9 Public displays

Public displays will be used to engage directly with the community to help identify and communicate issues of importance to specific audiences; for example, shopping centre displays in Howard Springs will be set up to engage with the community about the Howard Springs Accommodation Village.

6.9.10 Phone surveys

Where directed by Company, Contractor will undertake phone surveys in line with key milestones to gauge the level of general community support or to gather feedback on a particular issue.

6.9.11 Sponsorship

Where Contractor determines a community need, or where directed by Company, some sponsorship opportunities may provide Contractor with the ability to make a contribution above the usual scope of construction activity. This may support Company and Contactor to fulfil corporate social responsibility obligations and help to achieve broader business goals.

Where deemed appropriate and timely, Contractor may participate in sponsorship of community events to further engage with the community at a grassroots level and provide direct consultation opportunities.

6.9.12 Industry events

Some Industry events and conferences may be considered as further opportunities to engage with particular interest groups such as industry colleagues, government representatives and some community members, in particular from the business community.

6.9.13 Site visits

Visits to Project construction sites and facilities may be arranged for key community stakeholders, although health and safety concerns must always remain the top priority when determining whether these activities are appropriate. Contractor will support Company with construction site visits which may be popular with Australian and Japanese Government, business and community representatives. This may require high levels of resourcing and liaison during the construction period. Safety issues, such as site inductions and PPE will need to be identified and protocols defined to ensure minimal impact to the construction schedule.

6.9.14 Media

Media commentary about the Ichthys Project can significantly influence public opinion. For this reason media is a key Project stakeholder, particularly in regional communities such as Darwin where the Project has a very high profile.




While Company engages media as an important tool to manage Project issues and favourably influence community perceptions, Contractor will not actively engage the media without the direction and support of Company, as per the agreed communications protocols.

Contractor CRM will advise Company in a timely and accurate manner where potential media interaction is anticipated.

The CRWG will meet on a weekly basis to identify and manage any community issues. Media risks and opportunities will be discussed and communicated upward if required. This group will help identify issues that could potentially attract media attention.

In conjunction with Company, Contractor will generate communications plans on which Company may base media engagement plans. Contractor will provide briefing notes to Company for significant events and Project milestones, as required.

6.9.15 Advertising

Advertising is an effective means of communicating key messages to the community, in a controlled manner.. Advertising can be used to correct misinformation, educate and reinforce messages, or communicate important information to the community such as roadworks, traffic haulage routes, or community events.

Advertising across a diverse range of channels can support the promotion of the Ichthys Project and assist with recruitment. Contractor will advertise for recruitment and general information in the key local media outlets, to support Company advertising efforts throughout the construction phase.

6.9.16 Construction card—letterbox drops

Letterbox drops of professionally designed construction cards will take place as required. The content will change as construction activities change. The cards will be placed into letterboxes or tied to fences where appropriate to provide specific information to communities in discreet locations who are most highly impacted. The content will include the same advice provided to the broader community but with more detail. The content will be provided by Contractor and Subcontractor construction personnel and a copy will be provided to Company.

6.10 Promoting the joint venture

JKC Australia LNG is a joint venture between JGC Corporation, KBR (Kellogg Brown & Root Pty Ltd), and Chiyoda Corporation.

Each joint venture partner provides a high level of technical and strategic input in their participation in the Ichthys Project onshore LNG facilities construction phase.

All construction phase public communications generated by Contractor should include the logo in Figure 6.1:

Figure 6.1: JKC Australia LNG Logo




6.11 Community grievance management procedure

The Company Community Grievance Management Procedure provides the guiding standard process for Contractor to respond to and resolve grievances raised by the community that cannot be resolved by Contractor in the first instance, or by the CRWG. The procedure covers grievances linked to the direct or indirect consequences of activities carried out by Contractor and will also be used to record positive feedback and acknowledgements by the community and stakeholders.

The procedure provides the community with a mechanism to give feedback and raise grievances related to the impact of the construction of the Project. It enables Company and Contractor to respond to and to manage grievances in an efficient and timely manner.

Providing the community with an opportunity and process to communicate directly with Contractor and Company will help protect and potentially enhance reputations and reduce the potential risk of issues being elevated to a media or political level.

The Contractor stakeholder management database system will enable community relations to log complaints and responses; will allow the issues to be tracked, evaluated and reported, and will provide a tool for integration with the Company Stakeholder Relationship Management System within the SAP system. The database system will incorporate:

Community Grievance Register

Stakeholder Issues Register

Stakeholder Database

SRM+ data and analysis reports

media analysis reports

phone poling results.

Note: The Community Grievance Management Procedure is an internal term only and is consistent with the terminology within the International Finance Council guidelines. In external communications the procedure will be known as “community feedback” and will include the feedback options of [email protected] and the community feedback line (1300 724 795).

6.12 Public risk and incident communications

Activities such as increased traffic volumes for materials and equipment transport and increased marine traffic in Darwin Harbour may pose risks to the community.

Company and Contractor will work together to alert the community to any potential risks that may be present during this period.

The CRWG will meet regularly to identify and manage public communications around potential risks to the community during the construction phase.

In the case of specific incidents, Contractor will be responsible for communication with the community and will do so in close liaison with Company.

The EAM and CRM will support and/or participate in activities associated with Contractor crisis management where appropriate.

6.13 Lessons Learned

Contractor will establish a register to capture opportunities for improvement for Community Relations activities during the course of the construction phase, to be known as Lessons Learned.




7. THIS WILL INCLUDE IDEAS THAT MINIMISE COST AND IMPACTS TO CONSTRUCTION

SCHEDULE, INCREASE PRODUCTIVITY, STREAMLINE MANAGEMENT OF ISSUES,

STAKEHOLDERS AND EVENTS, AND GENERALLY HEIGHTEN THE AWARENESS OF

THE IMPORTANCE OF GOOD COMMUNITY RELATIONS ACROSS THE

PROJECT.CONTRACTOR ENGAGEMENT

7.1 Community Relations Working Group

The Community Relations Working Group (CRWG) will meet regularly to identify, discuss, resolve and monitor community issues and communications for the day-to-day construction activities.

Permanent members of the working group will include:

Company External Relations Manager

Company community relations coordinator (Darwin)

Company key communications and externalaffairs personnel (Perth)Contractor key community relations/external affairs personnel (Darwin).

Other Company and Contractor personnel may be asked to attend meetings as required.

The CRWG will review planned public communications for upcoming activities to determine appropriate channels and volume.

Company External Affairs Manager (and/or delegate) is a member of the Transport and Ports and Harbour subcommittees to ensure construction activities likely to impact on the community are captured and appropriate communication actions planned.

A Contractor community relations representative will also have membership of these committees during construction.

Company External Affairs personnel will also be in regular communication with the Director of Communications at the Department of the Chief Minister to ensure project–government communications are aligned and that existing departmental communication channels are utilised in support of this Plan. This information will be communicated to Contractor.

7.2 Public communication protocols

Company and Contractor have agreed to a set of overarching principles which guide communication protocols surrounding public engagement with media, government departmental staff, politicians, NGOs, and the wider community. These protocols are still being defined for various anticipated communication activities, setting out roles and responsibilities and identifying which actions are delegated to Contractor community relations personnel during the construction phase and which require approval from Company.

In summary, these protocols are brought together in a comprehensive matrix provided in the Contractor Advice to Subcontractor Part 3 and include the communication protocols and objectives for Company, Contractor and Subcontractor.

These protocols include the following:

Contractor may engage directly with external key stakeholders only with the prior approval of Company and in accordance with agreed communication plans and protocols.

Only Company-authorised personnel are able to make public statements on Project issues, unless otherwise agreed by Company External Affairs in conjunction with appropriate Contractor personnel.

All public complaints received by Project personnel shall be managed in accordance with the guiding principles in this Plan, the Company Community Grievance Management Procedure, and the Community Relations Working Group and its terms of reference.




SUBCONTRACTOR ENGAGEMENT

Contractor engagement with Subcontractors during the construction phase will include close management and guidance of key Subcontractor personnel to ensure timely and accurate delivery of information about construction activities and associated impacts. This will also the adequate provision of guidance to ensure risk to reputation of all organisations is minimised wherever possible.

Contractor has three key areas for guidance that are included in Subcontractor contractual documents and required to be taken into account before mobilisation to all construction sites across the Project. These are included in Appendices A, B and C.




APPENDIX A JKC JV ADVICE TO SUBCONTRACTORS: PART 1

COMMUNITY AND STAKEHOLDER ENGAGEMENT GUIDELINES Media

If approached by the media:

Do not consent to an interview or make a comment (remember that journalists believe that everything is on the record, and you are not an authority to speak on behalf of the project).

Refer media to the 1300 community hotline immediately (use provided business cards where possible).

If media trespass or interfere with work, stop work immediately and contact:

your supervisor who will then contact the Site Construction Manager

the community hotline.

Be polite and courteous at all times.

If media are present but are not trespassing nor interfering, then continue to work normally.

Be aware of listening devices and radios being monitored.

Be aware of the use of long-lensed cameras.

Ensure compliance at all times with all PPE and other HSE work requirements.

Do not do anything that may be used against your employer, Contractor, Company, or the Ichthys Project.

Do not react to being filmed if the media are on public land.

Do not react to media persistence or harassment off site.

Protestors

If you encounter protestors in the field:

Ignore them and continue to work normally.

Do not respond to taunts, criticism or abuse.

Do not comment or engage in conversation.


If protestors trespass onto the site, immediately contact:

your supervisor

the community hotline

If protestors interfere with personnel or equipment, contact:

security who should then contact police where appropriate

your supervisor

the community hotline.

Do not try to prevent damage being done to equipment or the worksite; simply contact security.

Engage in passive resistance if touched; stop work and leave the site, if necessary.

If the protestors become aggressive, leave the area immediately, if possible, and contact security.

Do not abandon a vehicle or equipment unless remaining with it could result in personal injury.




Ensure that equipment is secured overnight.

Be aware that your UHF or VHF radios may be monitored.

Do not engage with protestors off site.

If a road is blocked, or access to site is denied by protestors:

Stop the vehicle.

Do not proceed through blockade, even slowly.

Ask politely to be let through.

Do not engage in an argument or become aggressive or abusive.

Ignore taunts, criticism or abuse.

Contact site security, who will attend the site.

If the protestors become aggressive, leave the area immediately, if possible.

Do not abandon a vehicle or equipment unless remaining with it could result in personal injury.

Do not do anything that may provoke the protestors (e.g. taking pictures).

Landholders/Neighbours

Personnel must make every effort to maintain good relations with the community, particularly those who are directly or highly impacted by our work. The following protocols must also be followed:

The most senior construction officer on site must be sure that appropriate notifications have been made to potentially the most directly impacted members of the community—this should be a line item in the pre-start activity.

Note: This notification must have included, in some detail, what work is proposed, when it will start, when it is most likely to finish (always be conservative where estimating), what will be seen, any other impacts, remedial works, subsequent timeframes for other notifications.

Contact the community hotline if there is notable pushback from any community members which may impact the construction schedule and incur costs, or provide potential for damage to reputation of Company, Contractor or Subcontractor.

Show respect to the landholder and any family, neighbours or associated property which may be highly impacted.


Be aware of any lifestyle, business or community activities that may conflict with the scheduled work, and plan work accordingly. Negotiate arrangements where appropriate. Where there is potential for conflict, escalate concerns to the Community Relations Working Group in a timely manner, providing options for mitigation at the location.

Do not block any access to properties in proximity of the construction activity at any time, day or night, without appropriate and timely notification processes in place.

Ensure that all workers on the site understand that improper behaviour will have serious consequences.

Always keep members of the public well clear of worksites, particularly children.

Ensure that all HSES requirements are met, particularly public safety, noise, dust and vehicle use.

Keep vehicle movements near neighbouring properties to a minimum, whenever possible.

Understand the traffic routes for access to and from worksites as detailed in the site Traffic Management Plans and always use existing roads and tracks where possible.




Take care to close gates, repair fences, repair roads or driveways and take all precautions to protect community interests.

Ensure that remedial work is done properly and in an agreed schedule with impacted community members.

Ensure that equipment and the work area are secure and safe before any construction site is left unattended.

Take the time to thank community members for their cooperation and advise them of any future work which may be required in the same location.

WHEN APPROACHED BY MEDIA, PROTESTORS AND/OR COMMUNITY MEMBERS

ALWAYS CALL THE COMMUNITY FEEDBACK LINE: 1300 724 795




APPENDIX B JKC JV ADVICE TO SUBCONTRACTORS: PART 2

PUBLIC IMAGE AND BRANDING OF ICHTHYS PROJECT DURING CONSTRUCTION PHASE

External Branding

All external branding for the Ichthys Project during the construction phase, for construction related activities, will carry the JKC Australia LNG (JKC) logo (Fig 1) and implemented in conjunction with this document. This construction phase for JKC in Australia shall be referred to as the “Ichthys Project onshore LNG facilities”. All the information contained herewith applies only to JKC Australia LNG branding that occurs on Australian soil. The JKC branding structure and use of logo must be approved first by the JKC External Affairs Manager and then by the JKC Project Director, prior to any external use by the Subcontractor, lower tier subcontractors and all suppliers to the Ichthys Project onshore LNG facilities. The branding structure and logo (Fig 2) associated with the preparatory stage of the Ichthys Project is the property of INPEX and Total and should not be used in an external (public) environment without the written permission of the Company External Affairs Department (Communications Manager). Without permission the logo should not be used on contractor or sub-contractor:

PPE

Vehicles

Equipment

Websites

Media releases

Publications

It is important to INPEX and Total that the brand value of the “fish” logo be protected during the high-risk construction phase as it will play an important ongoing role during operations at a later stage, from a gas marketing perspective. Likewise the words “Ichthys Project” and Ichthys LNG Project” – these are production brands, not to be confused with the construction phase. The use of the “fish” logo will be reserved only for INPEX signage, PPE, and other INPEX approved requirements.

Figure 1: JKC Australia LNG Pty Ltd logo Figure 2: INPEX Ichthys Project logo




All requests from third parties to use either the INPEX name or logo must be reviewed and approved by External Affairs, and items that could be included are:

List of customers for marketing purposes

Articles about their work for INPEX in internal publications

Case studies for marketing purposes (generally would require INPEX to be referred to in an generic manner)

Media releases that mirror INPEX generated releases

However, generally INPEX does not allow its name or logo to be used externally by other companies, nor does it endorse any equipment, product or service. This supports the belief that such endorsement may give the supplier an advantage, thus contrary to the corporation's philosophy of fair and equal opportunity for all.

Construction Signage

In special circumstances and with appropriate INPEX approvals in place, the INPEX “fish” logo (Fig 2) may be used on Ichthys Project signage, for example, at Blaydin Point and the Accommodation Village entrance statement signs, in accordance with the INPEX style guide.

For temporary signage during construction, for example, at Blaydin Point and the Accommodation Village, the term “Ichthys Project onshore LNG facilities” in text only, should be used, along with the JKC logo and any other logos as approved by the JKC External Affairs Manager, then Project Director.

Permanent entrance statement signage at the Accommodation Village and Blaydin Point will be determined by INPEX.

PPE

JKC PPE can include Ichthys Project onshore LNG facilities text only, in the appropriate ‘mangrove’ green, which represents the colour of the tail of the fish in the INPEX “fish” logo.

The green colour codes are: PMS 348 C, CMYK C100M0Y85K24, RG B R 0G136B82.

The correct font can also appear in black if colour use on some items does not meet objectives.

Ideally the PPE logo structure would be applied to JKC, Subcontractors, and also lower tier subcontractors who have specific personnel working on the Ichthys Project onshore LNG facilities who require PPE over a lengthy period of time.

The Ichthys Project PPE logo structure would look similar to these two examples:




JKC Australia LNG LAING O’ROURKE

Ichthys Project Ichthys Project

onshore LNG facilities onshore LNG facilities

The Ichthys Project onshore LNG facilities should always include both upper and lower case letters and should never appear in capitals only. Subcontractors and suppliers can determine for themselves if this rule applies to their text sitting above the Ichthys Project onshore LNG facilities, however, it is preferred that symbols or larger graphics are not included on the PPE. All PPE logos must be approved by JKC External Affairs Manager, then JKC Project Director.

It is expected that all Subcontractors and appropriate suppliers, conform to this guideline for PPE for consistency across the Project construction phase.




JKC JV ADVICE TO SUBCONTRACTORS: PART 3

COMMUNICATION MATERIAL APPROVALS PROTOCOL

Criteria

Group 1 (Ichthys Joint Venture): Must have Ichthys Joint Venture approval

Group 2 (JKC JV partners: JGC, KBR & Chiyoda): Must have JKC JV partners’ approval and cc to INPEX

Group 3 (Operational – Community Relations Working Group): Requires Ichthys Project Community Relations Working Group approval only, but cc INPEX

Note: The protocols for communication material approvals for the JKC Ichthys LNG Joint Venture for offshore activities must always be distinguished by its name and separate logo/branding, and then be managed in the same way as for Group 2. Therefore, the applicable protocols must cascade down to all subcontractors and suppliers associated with these activities.

Protocol

All Group 3 materials prepared by Contractor and/or Subcontractor (with input as required from INPEX):

Regardless of author, forward draft materials to JKC External Affairs Manager for checking.

Forward to JKC Project Director for approval:

- Each JV partner is responsible for seeking internal approvals – JGC, KBR, Chiyoda

Forward to JKC External Affairs Manager for returning to author for distribution to the appropriate channels, copying Community Relations Coordinator responsible for managing public materials.

Provide Company with a copy of the approved materials and plan for distribution and timing.

Coordinator to ensure materials appropriately filed in JKC system.

Approval time by Project Directors is a maximum of 24 hours.

All Group 2 materials prepared by JKC JV and/or Subcontractor:

Forward to JKC JV Community Relations Manager for QA check.

Forward to JKC JV External Affairs Manager for progressing to JKC Project Director.

JKC Project Director to seek internal approvals from JGC and Chiyoda. JKC External Affairs Manager to seek internal approvals from KBR and integrate all JV responses

External Affairs Manager forwards to Company for further approval.

Company returns approved document along with Total’s approval to JKC External Affairs Manager in the agreed timeframe.

External Affairs Manager forwards to Community Relations Coordinator with responsibility for managing and distributing all approved JKC JV public communications materials.

Materials are filed appropriately in JKC JV system.

The approval time for JKC JV Partners to JKC JV personnel is 24 hours.

The approval time for Company back to JKC JV is 24 hours.

If materials are not returned in the agreed timeframe, the JKC JV personnel will liaise with Company and/or JKC JV Partners to determine the reason for delay and to revise the date.

The Approvals Register is updated by JKC JV Community Relations Coordinator.

All Group 1 materials generated by JKC JV Partners, JKC JV, the Ichthys Project Community




Relations Working Group, Subcontractor, or any lower tier subcontractors and suppliers will be forwarded to Company as Operator for the Ichthys Project. All materials must be filed appropriately in the JKC JV system and distributed as for Group 2 materials.

Approval times for Companyare as per Ichthys Joint Venture approval protocols.

Any items for publication will be discussed at the weekly Community Relations Working Group meeting.

It is understood that sensitive, complex and lengthy documents will require additional time to review. As these are normally long-lead items, they will be flagged well in advance and reasonable approval times will be agreed well ahead.




COMMUNICATION MATERIALS PROTOCOL—TABLE OF DETAIL

The following table lists the types of communication materials anticipated on the Ichthys Project during the construction phase, along with the required levels of approval and input as outlined in the criteria and protocols above.

Group 1

Communication Ichthys Joint

Venture

JKC JV & JV Partners

Community Relations WG

Subcon- tractor / Supplier

INPEX FYI

Media releases about INPEX matters (not Project-related)

Briefings and briefing notes for elected representatives

Letters to residents/stakeholders about actions being taken on behalf of the Ichthys Joint Venture where work is not yet contracted to JKC JV or Subcontractor

Newsletters for general public distribution regarding project/progress

Project display materials, e.g. posters for public information sessions

Invitations to public events

Project fact sheets

Advertisements; advertorials and general articles about the project

Logos/branding

Key messages

Media opportunities/milestones/media releases

Group 2

Communication/Activity Ichthys Joint

Venture




INPEX FYI

Invitations to events, including those initiated by JKC JV, Community Relations Working Group or Subcontractors/Suppliers

Group 3

Communication/Activity Ichthys Joint

Venture




INPEX FYI

Letters to residents about work being undertaken in relation to construction activity in their area

E-mail updates for stakeholders

Contributions to school newsletters




Flyers regarding information sessions

Advertisements in local/regional papers relating to traffic changes or specific construction activity, e.g. road closures

Fact sheets, for specific activities/concerns such as construction, blasting, environment

Q&A sheet, e.g. for construction in a sensitive area

Construction cards

Ichthys Project web site

Response to 1300 “hotline” or web site inquiries

PowerPoint presentations

Reports and templates reporting requested by the Ichthys Joint Venture

MEDIA AND ADVERTISING

Group 1

INPEX logos and branding Ichthys Joint

Venture




INPEX FYI

Any media requests for information or comment about the Project

Inquiries about project activities, e.g. work updates, stats

Media opportunities and photo opportunities for Chief Minister or other elected representatives

Advertisements for activities, e.g. EIS activities

Advertorials or features to mark milestone events

Group 2

JKC JV logo and branding Ichthys Joint

Venture




INPEX FYI

Interview or comment from JKC JV Partners regarding work of Company or JKC JV that does not fall into Group 1

Advertising for JKC JV staff

Advertising JKC JV Partner and JKC JV achievements




Group 3

JKC JV logo and branding Ichthys Joint

Venture




INPEX FYI

Provision of facts in response to a specific media inquiry on operational detail, e.g. traffic control, road closure, machinery movements

Copy and photos for industry publications in response to a direct request; a request to assist writers and photographers from technical/construction publications

Establish a working relationship with local/regional media to open communication channels for issues raised at community level needing clarification or informed comment to balance story source.

Advertisements for operational activities, e.g. road closure, resident meeting

Note:

Members of the Ichthys Project Community Relations Working Group are all communication professionals experienced in dealing with the media. It must be assumed that the assessment of whether a media inquiry/response is a Group 1, 2 or 3 responsibility will be properly made and that necessary consultation will occur to ensure there is an appropriate and timely response.

All organisations included in this Plan are regularly required to provide an updated list of names and contact details of appropriate media-trained expert personnel as potential “talent” for media opportunities where media engagement has been formally approved through the processes detailed above.

Following is an example of the Media Release process:

A Subcontractor is awarded more work with the joint venture and wishes to announce this publicly. The following procedure would take place:

Contractor receives draft from Subcontractor, reviews to ensure information and messaging is accurate for Contractor requirements, and then forwards to Company.

Company Package Manager reviews to ensure information and messaging is accurate for INPEX/Total requirements and forwards, copying in appropriate internal personnel, to External Affairs (Bill Townsend, Tim Larcombe, Ilka Burnham-King) who review and arrange relevant approvals in Perth and Tokyo and with Total as required.

Company External Affairs advise changes to Company Package Manager who then advises Contractor.

Contractor advises Subcontractor, records timing and distribution of media release, and provides this information to Company Package Manager.

Company Package Manager advises timing and distribution details to Perth External Affairs.

External Affairs submits to KBR media group in Adelaide who submit to Houston KBR for approval. This can only occur after Company Package Manager has Total and INPEX approvals.

KBR media approves and External Affairs provides full approval to Subcontractor.



APPENDIX CCommunity and Project Bulletin

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Ichthys Project Bulletin

INPEX.com.au©INPEX August 2018

Three well-known Territory businessmen have taken their Ichthys LNG stories to the nation’s capital to promote the capabilities available in the Top End.

Robert Wilson from Territoria Civil, Cross Cultural Consultants’ Jason Elsegood and Greg Haigh from Regional Asset Maintenance Services joined a small business delegation to discuss the economic and social impact of the Ichthys LNG Project.

The delegation met with Federal politicians and public servants to share the story of their individual business’s interactions with Ichthys and the opportunity major oil and gas projects present to Northern Australia.

Welcome to the August 2018 Ichthys Project bulletin. In this edition, we celebrate a number of Territorians who have expanded their careers and businesses working with the INPEX-operated Ichthys LNG Project. Read about locals taking up an apprenticeship, a Winnellie business that has doubled the size of its workforce and two organisations lending a hand in the community.

Community BulletinIssue 33 | August 2018

Local businesses share their Ichthys LNG story

INPEX General Manager External Affairs and Joint Venture, Bill Townsend said the event provided business representatives with the chance to speak directly to national decision makers.

“At INPEX we are committed to contributing to the economic development of host countries and communities,” Mr Townsend said.

“We have already invested billions of dollars in the Territory and Ichthys will continue to underpin the economy for decades to come – because we know that behind those billions are real businesses, and behind those businesses are real people.”

INPEX’s Bill Townsend with Darwin businessmen Jason Elsegood, Robert Wilson and Greg Haigh.

INDRA28-SEP-2018


INPEX.com.au

A dry season morning cruise on Darwin Harbour in July was the stage to showcase the global scale of the INPEX-operated Ichthys LNG Project.

INPEX President Director Australia, Seiya Ito, hosted the Minister for Foreign Affairs, the Hon Julie Bishop MP along with 70 Canberra-based ambassadors and high commissioners on a harbour-view tour of the Ichthys LNG onshore processing facilities at Bladin Point.

Many of the countries represented in the delegation have been involved in the development of Ichthys LNG.

“Financing the Project involved 24 commercial banks and eight export credit agencies from Japan, the Republic of Korea, the Netherlands, Germany, France and Australia,” Ito-san said.

“At peak, there were more than 30,000 people working on the Project across four continents.”

INPEX President Director Australia Seiya Ito with the Minister for Foreign Affairs the Hon. Julie Bishop MP.

Careers continue with Ichthys LNG

Eddie Clarke and Zabedah Baharuddin are continuing their careers with Ichthys LNG.

Three local apprentices have seized opportunities to continue their careers supporting INPEX on Ichthys LNG.

Eddie Clarke, Zabedah Baharuddin and Krystal Noakes had gained experience as part of the Ichthys LNG Project’s construction workforce, before taking up apprenticeships with INPEX’s lead onshore maintenance contractor TRACE.

Father-of-two Eddie was one of the first 10 employees hired by TRACE, initially as a General Service Technician.

“I jumped on the opportunity to undertake an apprenticeship as a mechanical fitter and progress my career in the oil and gas industry,” Eddie said.

For former lifeguard Zabedah, her electrical apprenticeship offered the opportunity to combine two of her passions.

“I love maths and science and this is the chance to put those passions together,” Zabedah said.

“Working on one of the biggest projects in the world has definitely given me a head start toward a potential future as an engineer.”

Showcasing Ichthys LNG to the world

INDRA28-SEP-2018


Max Nicholson has transformed his family-owned business.

INPEX.com.au

A family-owned business has doubled in size after successfully remodelling to target service and supply opportunities in the oil and gas sector.

Established by Richard Nicholson in 1983, Winnellie Hydraulics is now run by his son Max.

“When construction of the Ichthys LNG Project started in 2012, we saw the opportunity to grow our business by targeting the resources industry,” Max said.

“From that beginning we are now supplying Ichthys onshore and offshore facilities.”

Hundreds turn out for industry forumMore than 200 business people attended an industry forum in May to hear about contracting opportunities to support the operations of the Ichthys LNG onshore processing facilities in Darwin.

INPEX Maintenance Manager Mark Wilson provided an overview of INPEX’s business values and the contracts awarded to support INPEX during operations in Darwin.

A number of INPEX’s contractors and subcontractors also attended the event.

“It was a good opportunity to update the local business community, but more importantly it gave attendees the chance to talk to our primary contractors and promote their capabilities directly,” Mr Wilson said.

Superintendent Stuart Miles, from INPEX’s lead onshore maintenance contractor TRACE, updated the audience on the status of their subcontract packages and commitment to building a local workforce.

“I was really impressed at the strong level of interest in working with INPEX and TRACE and welcomed the opportunity to talk to business representatives from across the service and supply sector,” Mr Miles said.

Max said supporting the construction phase of Ichthys LNG had built his business’s understanding of how mega projects operate and where long term opportunities might lie.

As demand for their service has grown, Winnellie Hydraulics has doubled its workforce to 10.

“We have invested locally in employees and equipment but we are also globally connected with specialist manufacturers worldwide who we deal with on a daily basis,” said Max.

Local business doubles in size

INPEX Maintenance Manager Mark Wilson and TRACE Superintendent Stuart Miles at the forum.INDRA

28-SEP-2018


The Ichthys LNG Project is a Joint Venture between INPEX group companies (the Operator), major partner Total, and the

Australian subsidiaries of CPC Corporation Taiwan, Tokyo Gas, Osaka Gas, Kansai Electric Power, JERA and Toho Gas.

Contact usGeneral community feedback 1800 705 010

INPEX.com.au [email protected]

Foodbank NT has lifted its capacity since the donation of a forklift by the Ichthys Project workforce.

“Foodbank staff and volunteers use the new forklift up to 50 times a day to unload freight, manage stock and move produce as pallets of donations come in,” Foodbank NT CEO Paul Avery said.

“Our old forklift had reached the point where it became unserviceable and this donation from the Ichthys workforce has made a huge difference in the day to day running of our business,”

Foodbank was established in the NT eight years ago to redistribute food and groceries to Territorians needing support and minimise food waste.

The not-for-profit agency receives donations from food companies which are then distributed to 84 local agencies including The Salvation Army, Australian Red Cross and school breakfast programs.

The donations equate to more than 32,000 meals a month.

The INPEX-operated Ichthys LNG Project has strengthened its relationship with the Australian Volunteer Coast Guard Darwin by donating 16 high-quality personal flotation devices (PFDs).

The Project has supported Coast Guard Darwin since 2011 and the new PFDs were warmly welcomed.

“These vests have their own personal location beacons, so they will be a great help to our crews in recovery situations,” Flotilla Commander Fiona Villaflor said.

“The donation will also help our volunteers, who currently bear the cost of buying their own PFD.”

Coast Guard Darwin patrols seaward to North Gutter, West to the Peron Islands and East to Cape Hotham, assists NT Police in marine search and rescues as well as providing support to community events.

“Like INPEX and Ichthys LNG, Coast Guard Darwin has safety at the focus of all its activities,” INPEX General Manager Operations Onshore Dave Dann said.

“We are proud to support this important community organisation.”

INPEX and Ichthys LNG are proud to be part of the Northern Territory community.

Applications are now open for round two of the 2018 INPEX Australia Community Sponsorship and Investment program until 31 August 2018.

Under the program, up to A$5,000 may be available for initiatives that support education and training, health and well-being, local businesses and our community.

Sponsorship guidelines and application forms can be found at INPEX.com.au

INPEX General Manager Onshore Operations Dave Dann (centre) with Dean Breward and Fiona Villaflor from Coast Guard Darwin.

Peter Chandler (L) and Paul Avery (R) from Foodbank NT with INPEX’s Steve Greene.

Staying safe on the water

Supporting our community

Foodbank NT gets a lift

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Issue # 242 22 June 2018

The first half of 2018 has seen the achievement of some significant milestones on the Ichthys Project Onshore LNG Facilities.

Most notably, last month JKC handed over the first LNG train to INPEX. This was the culmination of a huge effort and collaboration by construction, commissioning and operations teams from INPEX, JKC and our subcontractors.

With the construction phase of the Project nearing completion, this is the last edition of the JKC Community Bulletin.

The Bulletin started in March 2012 as a newspaper advertisement to provide information regarding construction activity and help minimise community impacts. Over the last six years it has evolved to celebrate not only important Project milestones, but also the people behind the Project.

My first trip to Darwin was in January 2012 and I have been based in Darwin since January 2013. It has been a privilege to live and work in your community in such a special and unique part of the world.

We opened our Construction Employment and Mobilisation Centre in May 2012, just before the ground breaking ceremony with the Prime Minister and Chief Minister. From those early beginnings we have worked very hard on local

employment and local business participation outcomes, and are very proud of our record in both areas. Above all, we have been focused on building a strong incident and injury free culture at all Project locations.

It has been exciting to see the plant site change throughout the construction phase to reveal the state-of-the-art facility in place today.

I would like to thank the people of Darwin, Palmerston and the rural area for your support during this time. It has enabled us to deliver a legacy asset that will benefit the Territory economy and community for generations to come.

I hope our Bulletin has kept you informed of Project activity and helped minimise inconvenience. For more news and information about the Project, please visit the INPEX website.

Regards,

John Bramley Project Director JKC Australia LNG

Construction of the Ichthys Project Onshore LNG Facilities is almost complete. Inset: Bladin Point in September 2012.

INDRA28-SEP-2018


http://www.inpex.com.au/news-media/

You can contact our Community Relations team with any Project related enquiries by calling our Community Feedback line on 1300 724 795.

Berry Springs residents Candice Tucker and Tiaki Taiawa were reunited with their pet Nicky in 2015 after the dingo was found onsite.

Nicky had been missing for more than a month before Leighton Contractors Environmental Advisor John Ross recognised the dingo and its blue collar from a flyer advertising the pet as missing. Nicky was safely trapped onsite and returned to her grateful owners who said up to that point they’d all but lost hope in finding him. “The odds of getting him back is like winning the lottery,” Candice said. “We are so thankful.”

Top: Bianca Argoon and Nicole Davenport safely capture Nicky onsite. Right: Candice Tucker, Nicky, and Tiaki Taiawa.

In 2013, one of the highest points onsite was the Temporary Office Facilities’ communications dish. The perfect home for a new nest, or so thought one white bellied sea eagle, who promptly set up house. Special permissions had to be sought and the nest was carefully moved to a tall tree nearby offsite where the eagle soon laid its eggs. Photo credit: Jim Bendon, Wikicommons.

Djuki Mala danced at NAIDOC in 2015.

Buslink VIVO Assistant Duty Manager Jacqueline Taheny delighted her colleagues when she competed in the 2017 UCI BMX World Championships in the US. The mother of three started riding after watching her son “have all the fun”.

Corinne ‘Queenie’ Warhurst is an Emergency Response Contact Coordinator with Fire and Safety Australia onsite and a world champion Jiu-Jitsu athlete. In 2015 the mother of three defended her World Master title after competing in the US. At this year’s International Women’s Day event, held onsite, Queenie joined a panel of senior female leaders and encouraged women to be confident and courageous.

INDRA28-SEP-2018



JKC estimates that, during the construction phase of the Project, workers have helped raise more than $1 million in cash and in-kind donations.

Project worker Johnny Andrikopoulos, who jumped out of a plane last year to raise money for young Territorians affected by cancer, summed it up best when he said Project workers were a naturally generous group.

“Construction workers always dig deep when it comes to helping other people,” he said.

Companies and individuals onsite have championed local causes and banded together to help those in need.

One of the biggest fundraisers which brought together workers from all scopes of work on the Project has been the annual Christmas Charity Drive.

For the past three years workers packed donated food, toys and other essential or fun items into truck after truck. The goods were delivered to charities for distribution to Territorians in need across the Top End.

Companies who work on the Project have sponsored local

sports teams, events and helped raise funds for medical equipment and sick kids. Workers have also found ways to practically recycle items onsite. Personal protective equipment such as pants and boots are donated to people who are homeless and to job seekers.

One of the highlights on the Project calendar for five years running was the Employee Fun Day. In 2017 More than 3,500 people flocked to Freds Pass Reserve to enjoy a day of free activities and entertainment including face painting, rock climbing, a petting zoo, pony rides and a custom built scaffolding structure with two flying foxes. Site tours were again a huge hit, with almost 1,700 people taking the rare opportunity to have a look at the world-class project their loved ones worked on.

JKC Project Director John Bramley thanked Project workers, who collectively have inspired such goodwill throughout Darwin, Palmerston and the wider community.

“Many of these initiatives are driven by individual Project workers or subcontractors onsite. Their generosity is heartening and adds to the positive legacy we aim to leave in this community,” he said.

Kentz electrician Johnny Andrikopoulos, seen here jumping out of a plane over Darwin to raise funds for CanTeen, is just one of countless Project workers who have generously given to help others.

INDRA28-SEP-2018


The following information aims to inform the community of vehicle movements associated with the Project.

Transporting the Project workforce is a complex and highly organised logistical operation. The majority of our construction workforce are transported by JKC’s bussing subcontractor, Buslink VIVO. Some workers also commute in site specification light vehicles.

In undertaking bus transportation, as with everything we do, the safety of the community and our workers is our highest value. We all need to safely share our roads and highways. We travel along routes approved by the Northern Territory Government, as shown below.


INDRA28-SEP-2018


Please note each bus may be used more than once from different locations

22 buses daily carrying workers from Darwin and Palmerston to Bladin Point

55 buses daily from Manigurr-ma Village to Bladin Point

One bus daily from Bladin Village to Bladin Point

One bus every hour from Manigurr-ma Village and Bladin Village to Darwin International Airport

16 buses daily from Darwin International Airport park’n’ride to Bladin Point

Five buses daily from Yarrawonga park’n’rides to Bladin Point

Four buses daily from the Coolalinga park’n’ride to Bladin Point

One social run from Manigurr-ma Village to Darwin and Palmerston from Monday to Friday with up to eight runs on weekends

One daily social run from Bladin Village to Darwin and Palmerston

Four semi trailers daily carrying material from East Arm Port via Berrimah and Wishart roads, Elrundie Avenue, Channel Island and Wickham Point roads to site

Two road trains daily carrying crushed rock from Mt Bundey quarry via the Arnhem and Stuart highways, Jenkins, Channel Island and Wickham Point roads to site

Five road trains / semi trailers daily carrying material from Winnellie via Berrimah and Wishart roads, Elrundie Avenue, Channel Island and Wickham Point roads to site

Two road trains / semi trailers daily from interstate via Stuart Highway, Jenkins, Channel Island and Wickham Point roads to site


INDRA28-SEP-2018


A marine safety zone, declared by the Regional Harbourmaster, is in effect in the waters near the

Ichthys Project Onshore LNG Facilities

Please observe the zone so we can all share the harbour safely

The Regional Harbourmaster’s Notice to Mariners can be found at www.nt.gov.au/marine

Image supplied by INPEX

INDRA28-SEP-2018


APPENDIX DEmergency Response Plan

INDRA28-SEP-2018


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INDRA28-SEP-2018




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INDRA28-SEP-2018


APPENDIX ESpent Water Re-Use Permit Examples

INDRA28-SEP-2018


Dewatering PermitAccountable:

Status: Closed (23/06/2018)Composed: 28/05/2018 Created by: Jemima PARISH Document Number: 004077Hierarchy

OPS-1/Bladin Point/C 300/OPS-1/Ventia/

Part A - Application(Completed by Subcontractor Representative)Date From: 28/05/2018 12:00 Date To: 28/05/2018 16:30Time From: 12:00 Time To: 16:30Permit Applicant Full Name:

PARISH Jemima

Specific Point of Discharge:(Please use grid reference letters and numbers e.g. E5)

G - 2 Show Grid Map Volume to be discharged [kL]:

5 KL

Source of water:(Explain where are you dewatering from - i.e. pit A200 area and provide GPS coordinates)

Water Tank to be emptied and water to be used for dust suppression

Part B - Permit Type(Completed by Subcontractor Environmental Representative)Permit Type: Surface water DWPNote: For all Groundwater DWP approvals, laboratory certificate of analyses for filtered heavy metals must be attached with each application.For all Hydrotest DWP approvals, laboratory certificate of analyses for filtered heavy metals and any other relevant contaminants “i.e. preservatives” must be attached with each application.Reuse of water for dust suppression or dust suppression in general is not to be conducted while it is raining, or if soil is saturated from previous excessive rain or other activities.Laboratory Certificate Attached:

No

Dewatering Method:

Reuse

Part C - Adhere to the following controls(Completed by Subcontractor Environmental Representative)pH is between 6 and 8.5: Yes Field pH reading: 7.11Field turbidity is below 75 NTU:

Yes Field turbidity reading [NTU]: 1.38

Visible oil sheen present on surface:

No

Floating scum or iron stain present:

No

Downstream inspected for potential impact:

No

Downstream drainage is clear of other works/users:

Yes

Erosion risk at point of discharge:

No If yes, are additional controls applied?

Additional controls:Water quality to be monitored: No If yes, select interval:

Page 1 of 2Dewatering Permit

5/09/2018https://s6.myosh.com/dylor/jkc/dewateringpermit.nsf/52176d01899ecad148256d10002...

INDRA28-SEP-2018


Will the pump draw sediment: No If yes, float attachment or sump is required. Is it installed and functional?

Weather forecast checked: YesAdditional information: No additional information

Note: Tank is located in company controlled area, reason for dewatering is to empty tank for removal from this area.Dust suppression will be outside of company controlled areas

Authoriser: DOWDALL RachelACKNOWLEDGEMENT

By signing this form I acknowledge that the above information is true and correct and that I am aware of and understand my obligations associated with dewatering activities and achieving compliance with the CEMP

and EPA7 approval. This activity should not have any negative impact downstream.

AuthorisationDate Authorised:

29/05/2018

Comments:

Submit it for ClosureActual Volume Discharged in kL:

5

Comments: Works complete. Dust suppression. Submit To: MANAL Lars

Permit ClosureComments:Refer To:

History: click to expand History

AttachmentsAttachments: 20180528 AB 9 Turbidity Test.jpg

20180528 AB9.jpg APPENDIX B_DWP_EMA water tank AB 9.pdf BPPW Monthly Data_March 2018.pdf



INDRA28-SEP-2018



Status: Pending ClosureComposed: 03/05/2018 Created by: Linda GARDNER Document Number: 004053Hierarchy

CCP-7/Bladin Point/EMA/CCP-7/CIVMEC/


GARDNER Linda


F - 23 Show Grid Map Volume to be discharged [kL]:

5


Discharge of treated concrete washout water.


No

Dewatering Method:

Reuse


Yes Field turbidity reading [NTU]: N/A


No


No


Yes


Yes


Yes If yes, are additional controls applied?

Yes

Additional controls: This permit will be retained within the Vac Truck throughout the duration of the dewatering operation.



INDRA28-SEP-2018


Water quality to be monitored: No If yes, select interval:Will the pump draw sediment: No If yes, float attachment or

sump is required. Is it installed and functional?

Weather forecast checked: YesAdditional information: There is the potential for erosion at the discharge location (during discharge)

although eroded material is captured within the existing EMA sediment basin. Turbidity will not be measured or monitored as dispensation is granted for discharge at the EMA discharge location.The sampling attached is a representative sample of all treated concrete water located within IBCs at the EMA. All water will be discharged at the JKC approved discharge location within the EMA (location F23).pH readings will be undertaken for each location and recorded on the Vac Truck Spoil Tracking Form.

Authoriser: KALIAPPAN KannanACKNOWLEDGEMENT




03/05/2018

Comments:


6

Comments: Tracking form attached.Submit To: STRANGER Michael



AttachmentsAttachments: DWP4053 Vac Truck Spoil Form.pdf

DWP4053 APPENDIX B_DWP PERMIT EVIDENCE.pdf DWP4053 Concrete Washout Water IBC.pdf DWP4053 Treated Concrete Washout water sample.pdf ATTUU8XD.pdf



INDRA28-SEP-2018



Status: Closed (09/07/2018)Composed: 23/04/2018 Created by: Rebekah GEAGEA Document Number: 004040Hierarchy

CCP-3/Bladin Point/B 200/CCP-3/Monadelphous/


GEAGEA Rebekah


K - 8 Show Grid Map Volume to be discharged [kL]:

40


Laydown 2 (E600) Oily Water Separator (OWS) treated water from overflow tanks. Will alleviate pressure from system capacity.Water is potable/rain water which is used for washing vehicles and then is treated by an OWS to separate the hydrocarbons. It then goes into the tanks to be recycled or stored.


Yes

Dewatering Method:

Reuse




No


No


Yes


Yes



Additional controls:Water quality to be monitored: No If yes, select interval:



INDRA28-SEP-2018



Weather forecast checked: YesAdditional information: Re-use for dust suppressionAuthoriser: STRANGER Michael

ACKNOWLEDGEMENTBy signing this form I acknowledge that the above information is true and correct and that I am aware of and understand my obligations associated with dewatering activities and achieving compliance with the CEMP



23/04/2018

Comments:


40

Comments: Reuse for dust suppression to be confined to MEA CCP-3 battery limits and must not cause ponding or erosion or otherwise adversely impact on downstream users

Submit To: DOWDALL Rachel



AttachmentsAttachments: ES1810225_0_COA.pdf

ES1810225_COC.pdf DSCN0255.JPG ATT2CHKQ.JPG DSCN0256.JPG DSCN0257.JPG 004040_Appendix B DWP_23042018.pdf DSC08942.JPG DSC08943.JPG DSC08944.JPG



INDRA28-SEP-2018


APPENDIX FDiffuser Design and Outfall Piping Plan

INDRA28-SEP-2018


O:\Engineering\Drafting\AutoCAD Files\C208-40C-C-SKE-522_0.dwg, 29/10/2015 9:32:58 AM, DWG To PDF.pc3

INDRA28-SEP-2018


APPENDIX GDischarge Permits

INDRA28-SEP-2018



Status: Closed (17/02/2018)Composed: 12/08/2017 Created by: Danie PRINSLOO Document Number: 003279Hierarchy

JKC/Bladin Point/C 600/JKC/JKC/


PRINSLOO Danie



25613.17


Multiple construction water from various sources entering the C600 - Water quality verified as per individual permits.Water quality acceptable for discharge via the MOF.This will be discharged via the MOFtwo weekly verification sampling undertaken by Greencap for this ongoing permit.


Yes

Dewatering Method:

Discharge




No


No


No


Yes



No

Additional controls: Multiple construction water from various sources entering the C600 - Water quality verified as per individual permits.


1/09/2018https://s6.myosh.com/dylor/jkc/dewateringpermit.nsf/e9e08e1aca205b7448256d1f0036...

INDRA28-SEP-2018


Water quality acceptable for discharge via the MOF.This will be discharged via the MOFtwo weekly verification sampling undertaken by Greencap for this ongoing permit.



No

Weather forecast checked: NoAdditional information:Authoriser: DOWDALL Rachel

ACKNO˜ L˜ D˜ ˜ M˜ NTBy signing this form I acknowledge that the above information is true and correct and that I am aware of and understand my obligations associated with dewatering activities and achieving compliance with the CEMP



12/08/2017

Comments:


25613.27

Comments: Temporary closure of permit while pH monitoring takes place by Greencap - 27/09/2017Temporary closure of permit - 1/11/2017Permit approved for closure, Greencap 2 weekly verification sampling of AOC basins attachedRefer to permit 3736 for future discharges permits




AttachmentsAttachments: Photos of AOC 10082017.pdf

AOCIN_100817 (NTU).JPG AOCIN_100817.JPG AOCIN_260717 (NTU).JPG AOCIN_260717.JPG AOCIN_290817 (NTU).PNG AOCIN_290817.JPG Appendix B DWP EVIDENCE 3279.pdf TMF FRP Calculation.pdf Discharge 1 - 555942_COC.pdf Discharge 1 - 555942-W_report.pdf Discharge 1 - 558641_COC.pdf Discharge 1 - 558641-W_report.pdf Discharge 2 - 560121_COC.pdf Discharge 2 - 560121-W_report.pdf Discharge 5 - 565291_COC.pdf Discharge 5 - 565291-W_report.pdf Discharge 5 - 565610_COC.pdf



INDRA28-SEP-2018


Discharge 5 - 565610-W_report.pdf Discharge 6 - 565785_COC.pdf Discharge 6 - 565785-W_report.pdf Discharge 7 - 565990_COC.pdf Discharge 7 - 565990-W_report.pdf Discharge 8 - 566841_COC.pdf Discharge 8 - 566841-W_report.pdf Discharge 9 - 567426_COC.pdf Discharge 9 - 567426-W_report.pdf Discharge 10 - 568265_COC.pdf Discharge 10 - 568265-W_report.pdf Discharge 11 - 569722_COC.pdf Discharge 11 - 569722-W-V2_report.pdf Discharge 11 - 570317_COC.pdf Discharge 11 - 570317-W_report.pdf Discharge 12 - 570320_COC.pdf Discharge 12 - 570320-W_report.pdf Discharge 13 - 570807_COC.pdf Discharge 13 -570807-W_report.pdf Discharge 14 - 571170_COC.pdf Discharge 14 - 571170-W_report.pdf Discharge 15 - 571772_COC.pdf Discharge 15 - 571772-W_report.pdf Discharge 15 - 571775_COC.pdf Discharge 15 - 571775-W-V2_report.pdf Discharge 16 - 572261_COC.pdf Discharge 16 - 572261-W_report.pdf Discharge 17 - 572671_COC.pdf Discharge 17 - 572671-W_report.pdf Discharge 18 - 573388_COC.pdf Discharge 18 - 573388-W_report.pdf Discharge 19 - 574543_COC.pdf Discharge 19 - 574543-W_report.pdf Discharge 19 - 574614_COC.pdf Discharge 19 - 574614-W_report.pdf Discharge 20 - 574545_COC.pdf Discharge 20 - 574545-W_report FINAL.pdf Discharge 21 - 575962_COC.pdf Discharge 21 - 575962-W-V2_report.pdf Discharge 23 - 578116_COC.pdf Discharge 23 - 578116-W_report.pdf Discharge 24 - 578781_COC.pdf Discharge 24 - 578781-W_report.pdf Discharge 25 - 578993_COC.pdf Discharge 25 - 578993-W_report.pdf Discharge 26 - 579012_COC.pdf Discharge 26 - 579012-W_report.pdf Discharge 27 - 579068_COC.pdf Discharge 27 - 579068-W_report.pdf Discharge 27 - 579263_COC.pdf Discharge 27 - 579263-W_report.pdf Discharge 22 - 576909_COC.pdf Discharge 22 - 576909-W_report.pdf Discharge 22 - 577145_COC.pdf Discharge 22 - 577145-W_report.pdf WDL211_Tides and sampling window_080118.pptx WDL211 MASTER TARP_080118.xlsm



INDRA28-SEP-2018



Status: Closed (19/09/2017)Composed: 18/09/2017 Created by: Rachel DOWDALL Document Number: 003416Hierarchy

JKC/Bladin Point/E 600/JKC/JKC/


DOWDALL Rachel


L - 1 Show Grid Map Volume to be discharged [kL]:

1237.1



Yes

Dewatering Method:

Discharge




No


No


Yes


Yes



Additional controls:Water quality to be monitored: Yes If yes, select interval: 24hours



INDRA28-SEP-2018



Weather forecast checked: YesAdditional information: DWP raised to record discharge event from AOC to MOF.

Time from last discharge - 23/08/2017 to 29/08/2017.DWPs open for discharge to AOC during above timeframe are listed below:3275, 3282, 3279, 3287, 3112, 3340, 3309, 3071Water quality to be monitored: Greencap sampling of MOF takes place per discharge event





18/09/2017

Comments:


1237.1

Comments: Approved for closure, retrospective DWP to collate information from multiple DWPs leading to MOF discharge from AOC.




AttachmentsAttachments: 560742�COC.pdf

560742-W�report.pdf AOC Holding �asin Fill Monitoring�290817.xlsx AOCIN�290817 (NTU).PNG AOCIN�290817.�PG DWP 3416.pdf



INDRA28-SEP-2018




JKC/Bladin Point/E 600/JKC/JKC/


DOWDALL Rachel


L - 1 Show Grid Map Volume to be discharged [kL]:

1444.6



Yes

Dewatering Method:

Discharge




No


No


Yes


Yes



Additional controls:Water quality to be monitored: Yes If yes, select interval: 24hours



INDRA28-SEP-2018



Weather forecast checked: YesAdditional information: DWP raised to record discharge event from AOC to MOF.

Time from last discharge - 5/09/2017 - 12/09/2017.DWPs open for discharge to AOC during above timeframe are listed below:3287, 3382, 3112, 3243, 3279, 3340, Water quality to be monitored: Greencap sampling of MOF takes place per discharge event





18/09/2017

Comments:


1444.6

Comments: Approved for closureAuthorised, retrospective DWP to collate information from multiple DWPs leading to MOF discharge from AOC.




AttachmentsAttachments: 563159�COC.pdf

563159-W�report.pdf AOC Holding �asin Fill Monitoring�120917.xlsx IMG�5059.�PG IMG�5062.�PG Appendix � - DWP 3417.pdf



INDRA28-SEP-2018




JKC/Bladin Point/C 600/JKC/JKC/


PRINSLOO Danie



126000


Multiple construction and commissioning waters from various sources entering the C600 AOC BasinsWater quality verified as per individual permits.Water quality acceptable for discharge via the MOF.This will be discharged via the MOFGreencap sample the MOF points per WDL 211 for discharges and will undertake 2 weekly verification sampling of AOC basins to confirm water quality remains acceptable.


Yes

Dewatering Method:

Discharge




No


No


No


Yes



Additional controls: Multiple construction and commissioning waters from various sources entering the C600 AOC Basins



INDRA28-SEP-2018


Water quality verified as per individual permits.Water quality acceptable for discharge via the MOF.This will be discharged via the MOFGreencap sample the MOF points per WDL 211 for discharges and will undertake 2 weekly verification sampling of AOC basins to confirm water quality remains acceptable.



Weather forecast checked: YesAdditional information: AOC basins discharge to the MOF under WLD211

Water quality sampling results will be attached to Extension of permit subject to uploading of water quality data from the 2 weekly sampling program by Greencap and showing acceptable water quality.Refer to DWPS 4082 and 4091 for MOF discharges for the dates 05/06/2018 to 14/06/2018





30/12/2017

Comments:


126000

Comments: Permit to be closed,SP-2D was handed over to Company with effect from 4th July 2018 Refer to permit DWP 4119 for AOC discharges to MOF post SPD-2 handover under OPS-1 basin management




AttachmentsAttachments: Appendix B DWP EVIDENCE 3736.pdf

Discharge 1 - 579250_COC.pdf Discharge 1 - 579250-W_report.pdf Discharge 2 - 579631_COC.pdf Discharge 2 - 579631-W_report.pdf Discharge 3 - 579719_COC.pdf Discharge 3 - 579719-W_report.pdf Discharge 4 - 580061_COC - Characterisation.pdf Discharge 4 - 580061-W_report - Characterisation.pdf Discharge 4 - 580456_COC.pdf Discharge 4 - 580456-W_report.pdf



INDRA28-SEP-2018


Discharge 5 - 580442-W_report.pdf Discharge 5 -580442_COC.pdf Discharge 6 - 580426_COC - Characterisation.pdf Discharge 6 - 580426-W_report - Characterisation.pdf Discharge 6 - 580768_COC - Characterisation.pdf Discharge 6 - 580768-W_report - Characterisation.pdf Discharge 6 - 581421_COC - Characterisation.pdf Discharge 6 - 581421-W_report - Characterisation.pdf Discharge 6 - 581423_COC.pdf Discharge 6 - 581423-W_report.pdf Discharge 6 - ES1802890_0_COA - Surfactants.pdf Discharge 6 - ES1802890_COC - Surfactants.pdf Discharge 1 - 579068_COC - Characterisation.pdf Discharge 1 - 579068-W_report - Characterisation.pdf Discharge 7 - 581431_COC.pdf Discharge 7 - 581431-W_report.pdf Discharge 7 - 581433_COC - Characterisation.pdf Discharge 7 - 581433-W_report - Characterisation.pdf Discharge 7 - ES1802888_0_COA - Surfactants.pdf Discharge 7 - ES1802888_COC - Surfactants.pdf Discharge 8 - 581590_COC.pdf Discharge 8 - 581590-W_report.pdf Discharge 8 - ES1802726_0_COA - Surfactants.pdf Discharge 8 - ES1802726_COC - Surfactants.pdf WDL211 MASTER TARP_160318.xlsm WDL211_Tides and sampling window_160318.pptx Discharge 25 - 587893_COC.pdf Discharge 25 - 587893-W_report.pdf Discharge 26 - 588106_COC.pdf Discharge 26 - 588106-W_report.pdf Discharge 27 - 588340_COC.pdf Discharge 27 - 588340-W_report.pdf Discharge 28 - 589067_COC.pdf Discharge 28 - 589067-W_report.pdf Discharge 29 - 589114_COC.pdf Discharge 29 - 589114-W_report.pdf Discharge 20 - 585563_COC.pdf Discharge 20 - 585563-W-V2_report.pdf Discharge 21 - 585925_COC.pdf Discharge 21 - 585925-W_report.pdf Discharge 22 - 586634_COC.pdf Discharge 22 - 586634-W_report.pdf Discharge 23 - 587148_COC.pdf Discharge 23 - 587148-W_report.pdf Discharge 24 - 586880_COC - Characterisation.pdf Discharge 24 - 586880-W_report - Characterisation.pdf Discharge 24 - 587149_COC - Characterisation.pdf Discharge 24 - 587149-W_report - Characterisation.pdf Discharge 24 - 587372_COC.pdf Discharge 24 - 587372-W_report.pdf Discharge 15 - 584453_COC.pdf Discharge 15 - 584453-W_report.pdf Discharge 16 - 584448_COC.pdf Discharge 16 - 584448-W_report.pdf Discharge 17 - 584654_COC.pdf Discharge 17 - 584654-W_report.pdf Discharge 17 - 584683_COC - Characterisation.pdf Discharge 17 - 584683-W_report - Characterisation.pdf Discharge 18 - 585078_COC.pdf Discharge 18 - 585078-W_report.pdf Discharge 19 - 585559_COC.pdf Discharge 19 - 585559-W_report.pdf Discharge 9 - 582316_COC.pdf



INDRA28-SEP-2018


Discharge 9 - 582316-W_report.pdf Discharge 9 - GREE50_180130_1_coc - MBAS.pdf Discharge 9 - RN1184922 - MBAS.pdf Discharge 10 - 582314_COC.pdf Discharge 10 - 582314-W_report.pdf Discharge 10 - GREE50_180130_2_coc - MBAS.pdf Discharge 10 - RN1184923 - MBAS.pdf Discharge 11 - 582483_COC.pdf Discharge 11 - 582483-W_report.pdf Discharge 11 - ES1803234_0_COA - Basin C Surfactants.pdf Discharge 11 - ES1803234_COC - Basin C Surfactants.pdf Discharge 11 - GREE50_180130_coc - Basin C MBAS.pdf Discharge 11 - GREE50_180201_coc - MBAS.pdf Discharge 11 - RN1184921 - Basin C MBAS.pdf Discharge 11 - RN1185479 - MBAS.pdf Discharge 12 - 582889_COC.pdf Discharge 12 - 582889-W_report.pdf Discharge 12 - ES1803600_0_COA - Surfactants.PDF Discharge 12 - ES1803600_COC - Surfactants.PDF Discharge 12 - RN1185250 - MBAS.pdf Discharge 13 - 583316_COC.pdf Discharge 13 - 583316-W_report.pdf Discharge 14 - 583526_COC.pdf Discharge 14 - 583526-W_report.pdf Discharge 8 - 581815_COC.pdf Discharge 8 - 581815-W_report.pdf Discharge 8 - ES1802886_0_COA - Surfactants.pdf Discharge 8 - ES1802886_COC - Surfactants.pdf Discharge 8 - GREE50_180125_coc - MBAS.pdf Discharge 8 - RN1184758 - MBAS.pdf WDL211 MASTER TARP_080518.xlsm WDL211_Tides and sampling window_080518.pptx Discharge 30 - 589341_COC - Characterisation.pdf Discharge 30 - 589341-W_report - Characterisation.pdf Discharge 30 - 589575_COC.pdf Discharge 30 - 589575-W_report.pdf Discharge 31 - 590035_COC - Charactersation.pdf Discharge 31 - 590035-W_report - Charactersation.pdf Discharge 31 - 590497_COC.pdf Discharge 31 - 590497-W_report.pdf Discharge 39.pdf Discharge 40.pdf Discharge 41.pdf Discharge 42.pdf Discharge 43.pdf Discharge 44.pdf Discharge 45.pdf Discharge 46.pdf Discharge 47.pdf Discharge 32 - 590958_COC.pdf Discharge 32 - 590958-W_report.pdf Discharge 33 - 591249_COC.pdf Discharge 33 - 591249-W_report.pdf Discharge 34 - 591399_COC.pdf Discharge 34 - 591399-W_report.pdf Discharge 35 - 591637_COC.pdf Discharge 35 - 591637-W-V2_report.pdf Discharge 36 - 592219_COC.pdf Discharge 36 - 592219-W_report.pdf Discharge 37 - 592233_COC Characterisation.pdf Discharge 37 - 592233-W_report Characterisation.pdf Discharge 37 - 592424_COC.pdf Discharge 37 - 592424-W_report.pdf



INDRA28-SEP-2018


Discharge 38 - 592633_COC.pdf Discharge 38 - 592633-W_report.pdf TARP Report_WDL211_May and June 2018.xlsm DV Report_WDL211_May and June 2018.pdf Discharge 51 - 600437_COC.pdf Discharge 51 - 600437-W_report.pdf Discharge 50 - 600178_COC.pdf Discharge 50 - 600178-W_report.pdf Discharge 52 - 600429_COC - Characterisation.pdf Discharge 52 - 600429-W_report - Characterisation.pdf Discharge 52 - 600977_COC - Characterisation.pdf Discharge 52 - 600977-W-V2_report - Characterisation.pdf Discharge 52 - ES1815959_0_COA - Characterisation.pdf Discharge 52 - 600443_COC.pdf Discharge 52 - 600443-W_report.pdf Discharge 53 - 600841_COC.pdf Discharge 53 - 600841-S_report.pdf Discharge 53 - 600841-W_report.pdf Discharge 54 - 602138_COC - Characterisation.pdf Discharge 54 - 602138-W-V2_report - Characterisation.pdf Discharge 54 - 602139_COC.pdf Discharge 54 - 602139-W-V2_report.pdf Discharge 55 - 602673_COC.pdf Discharge 55 - 602673-W-V2_report.pdf Discharge 56 - 602637_COC.pdf Discharge 56 - 602637-W-V2_report.pdf Discharge 57 - 602849_COC.pdf Discharge 57 - 602849-W-V2_report.pdf Discharge 58 - 603622_COC.pdf Discharge 58 - 603622-W_report.pdf Discharge 59 - 603738_COC.pdf Discharge 59 - 603738-W_report.pdf Discharge 60 - 604141_COC - Characterisation.pdf Discharge 60 - 604141-W_report - Characterisation.pdf Discharge 60 - 605045_COC.pdf Discharge 60 - 605045-W_report.pdf Discharge 52 - ES1816071_0_COA - MDEA.pdf Discharge 52 - ES1816071_COC - MDEA.pdf Discharge 53 - ES1815629 MDEA Typed Report.pdf Discharge 53 - ES1815629 coc - MDEA.pdf Discharge 53 - ES1815629_0_COA - MDEA.pdf Discharge 55 - ES1817008_0_COA - MDEA.pdf Discharge 55 - ES1817008_COC - MDEA.pdf Discharge 56 - ES1817009_0_COA - MDEA.pdf Discharge 56 - ES1817009_COC - MDEA.pdf Discharge 57 - ES1817164_0_COA - MDEA.pdf Discharge 57 - ES1817164_COC - MDEA.pdf Discharge 58 - ES1817695_0_COA - MDEA.pdf Discharge 58 - ES1817695_COC - MDEA.pdf Discharge 59 - ES1817815_0_COA - MDEA.pdf Discharge 59 - ES1817815_COC - MDEA.pdf Discharge 60 - ES1818148_COC - AOC MDEA.pdf Discharge 60 - ES1818833_0_COA - MDEA.pdf Discharge 60 - ES1818833_COC - MDEA.pdf Discharge 60- ES1818148_0_COA - AOC MDEA.pdf Discharge 51 - 600974_COC - Piperazine.pdf Discharge 51 - 600974-W-V2_report - Piperazine.pdf Discharge 52 - 600975_COC - Piperazine.pdf Discharge 52 - 600975-W-V2_report - Piperazine.pdf Discharge 52 - 600977_COC - Piperazine AOC.pdf Discharge 52 - 600977-W-V2_report - Piperazine AOC.pdf Discharge 50 - 240518_Field Records.pdf Discharge 52 - 280518 Field Records.pdf



INDRA28-SEP-2018


˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜˜



INDRA28-SEP-2018




JKC/Bladin Point/E 600/JKC/JKC/Monadelphus


PRINSLOO Danie



8100


Transfer of water contained within Condensate tank 1 bund (L-430-T-001) and Condensate tank 2 bund (L-430-T-002) to AOC holding basin and discharge to MOF.


Yes

Dewatering Method:

Discharge




No


No


Yes


Yes



Additional controls: This discharge is aligned with advice provided by NT EPA Environmental Auditor regarding the discharge activity under this permit as attached email -



INDRA28-SEP-2018


FW PR wash water spill and AOC management assessment.We will undertake sampling of the C600 basin and per WDL211 for discharges to Darwin Harbour.



Weather forecast checked: YesAdditional information: Initial pH and Turbidity readings are from AOC characterisation from

28.12.2017 (refer to attachment WDL211 MASTER TARP_120118.xlsm), most recent AOC characterisation will also be attached once provided from Greencap.Water within the condensate tanks contains ZOK27 as a result of an overfill of Chemical Sewer Pit 2 (752-SU-002) during the water wash of A200 PR Compressor Gas Turbine.Mass balance / Dilution calculations have determined the discharge water will have a ZOK27 concentration of 2.49 mg/L, which after 80 fold dilution through the outfall will result in the median concentrations at the mixing zone to be well below the LORs (MBAS = <0.05 mg/L; CTAS = <0.5 mg/) for both ionic and non-ionic surfactants at the mixing zone monitoring locations - refer to attached email FW PR wash water spill and AOC management assessment.Significant rain occurred over the 25 Jan to

Authoriser: BLACK AnthonyACKNOWLEDGEMENT




25/01/2018

Comments:


40,000

Comments: We have adopted the LOR value for ionic (MBAS) and non-ionic (CTAS) surfactants as the Darwin Harbour criteria for assessment under WDL211. The attached WDL xls results do not trigger WDL211 Condition 23.1 or 23.2 for all mixing zone medians for ionic and non-ionic surfactants. I note that the LOR for the CTAS LOR was 10 fold higher than we were expecting and used in discussions with ERM. Mass balance / Dilution calculations are as follows:1. We have results from the 23 Jan 2018 which show MBAS concentrations of <0.05 mg/L and CTAS concentrations of <5 mg/L2. If we use this as 5 mg/L worst case scenario in 8100 m3 of water on the 25 Jan 2018, which equates to 0.0625 mg/L after 80 fold dilution in the mixing zone which is considered to be Low risk for impacts to the receptors3. Additionally, since the 25th Jan 2018 when the volume of dilution was reported to be 8,100m3 a further 683mm of rainfall has fallen and resulted in the basins containing 37,113m3 of water. This water was sequentially diluted with clean rainwater to 37,114m3 during the discharge event which would have reduced the concentration by 4.5 fold and would have resulted in a mixing zone concentration of 0.015 mg/L, which is lower that original discussed with ERM. 4. The above concentration of non-ionic surfactants is considered to be Low risk for impacts to the receptors.

Submit To: BLACK Anthony



INDRA28-SEP-2018




AttachmentsAttachments: 20171228 Biweekly AOC Characterisation - 579068_COC.pdf

20171228 Biweekly AOC Characterisation - 579068-W_report.pdf WDL211 MASTER TARP_120118.xlsm FW PR wash water spill and AOC management assessment.msg Appendix B DWP EVIDENCE DWP 3801.pdf Condensate Tank 1 Bund.jpg Condensate Tank 2 Bund.jpg 3. WDL211 MASTER TARP_020218_V2.xlsm 4. Temporal mass balance analysis.docx 5. Additional impact assessment for ionic and non-ionic surfactants.msg



INDRA28-SEP-2018




JKC/Bladin Point/C 600/JKC/JKC/Monadelphus


PRINSLOO Danie



5100


AOC Chamber C, inlet chamber and header discharge to MOF Permit stands to cover the AOC to MOF discharge while TMF AGRU discharge to AOC is active


Yes

Dewatering Method:

Discharge




No


No


Yes


Yes



Additional controls: This discharge is aligned with advice provided by NT EPA Environmental Auditor regarding the discharge activity under this permit as per attached



INDRA28-SEP-2018


email 'RE: Evidence for AOC discharges for review pls'Discharge sampling per WDL211 for discharges to Darwin Harbour will be undertaken by GreencapControls as per the attached risk assessment;- Water is discharged to C600 under an approved DWP and in accordance with WDL211- Sampling will occur within the C600 basins and water will be discharged via the MOF under WDL211 - Receiving environment including methyl diethanolamine and piperazine- Relevant water quality conditions of WDL211-4 include 16/23/24 will be demonstrated to be achieved- Contingency sampling has been proposed where WDL211 notifications are triggered- Contingency plan for offsite disposal using licences subcontractor where quality is not acceptable



Weather forecast checked: NoAdditional information: Chamber C in AOC and MOF mixing zone, sampling for diethanolamine,

piperazine and WDL211 parameters at both locations will be undertaken by Greencap





05/06/2018

Comments:


5100

Comments: Activity complete, Permit for closureSubmit To: DOWDALL Rachel



AttachmentsAttachments: AOC - ES1815959_0_COA.PDF

Mixing Zone - ES1816065_0_COA.PDF Mixing Zone - ES1816070_0_COA.PDF Mixing Zone - ES1816071_0_COA.PDF Risk assessment - Potential for offsite impact from discharge of AMINE water to MOF

outfall.pdf RE Evidence for AOC discharges for review pls.msg Appendix B DWP EVIDENCE DWP 4082.pdf Basin C_FR_280518.pdf



INDRA28-SEP-2018


AOC - ES1815959_0_COC.pdf Mixing Zone - ES1816065_0_COC.pdf Mixing Zone - ES1816070_0_COC.pdf Mixing Zone - ES1816071_0_COC.PDF Paul Fridell endorses water discharge.pdf Discharge sampling 070618_Field Records.pdf Discharge sampling 090618_Field Records.pdf Discharge sampling 110618_Field Records.pdf Discharge sampling 130618_Field Records.pdf Discharge sampling 20180607 - 602139_COC.pdf Discharge sampling 20180607 - 602139-W-V2_report.pdf Discharge sampling 20180607 - ES1816667_0_COA.pdf Discharge sampling 20180607 - ES1816667_COC.pdf Discharge sampling 20180609 - 602673_COC.pdf Discharge sampling 20180609 - 602673-W-V2_report.pdf Discharge sampling 20180609 - ES1817008_0_COA.pdf Discharge sampling 20180609 - ES1817008_COC.pdf Discharge sampling 20180611 - 602637_COC.pdf Discharge sampling 20180611 - 602637-W-V2_report.pdf Discharge sampling 20180611 - ES1817009_0_COA.pdf Discharge sampling 20180611 - ES1817009_COC.pdf Discharge sampling 20180613 - 602849_COC.pdf Discharge sampling 20180613 -602849-W-V2_report.pdf Discharge sampling 20180613 -ES1817164_0_COA.pdf Discharge sampling 20180613 -ES1817164_COC.pdf



INDRA28-SEP-2018


Dewatering PermitAccountable: Status: Open

Composed: 13/06/2018 Created by: Jennypher SORBIER Document Number: 004091Hierarchy

MEC-2/Bladin Point/C 600/MEC-2/Monadelphous Engineering Associates/


SORBIER Jennypher



1400


AOC basins A and B to be discharged to the MOF outlet.Greencap doing all water analysis (NATA certified).MEA checked pH and turbidity from AOC basins A and B.


Yes

Dewatering Method:

Discharge




No


No


Yes


Yes



Additional controls: Results indicate that chemicals 2-Methyl-4-Isothiazolin-3-one and 5-Chloro-2-Methyl-4-Isothiazolin-3-one were <LOR and WDL211 parameters are also



INDRA28-SEP-2018


within the end of pipe criteria. This water is acceptable for discharge to Darwin Harbour under WDL211.Refer to attachments for water quality analysis and risk assessment



Weather forecast checked: YesAdditional information: Greencap sampling will be undertaken at MOF will include WDL211, Cooling

medium (2-Methyl-4-Isothiazolin-3-one and 5-Chloro-2-Methyl-4-Isothiazolin-3-one), and AGRU chemicals (MDEA and piperazine)





13/06/2018

Comments:Chambers A and B approved for discharge to MOF - refer to attachments 1 to 16Chambers will be equalised with chamber C and discharged to MOF. DWP 4082 approved for discharge of inlet and chamber C.Greencap sampling undertaken at MOF will include WDL211, Cooling medium chemicals (2-Methyl-4-Isothiazolin-3-one and 5-Chloro-2-Methyl-4-Isothiazolin-3-one), and AGRU chemicals (MDEA and piperazine)


1400

Comments: Basins dosed with citric acid and pH levels lowered to acceptable levels.Water discharged to the MOF and Greencap tested the water at the outlet

Submit To: KALIAPPAN Kannan


AttachmentsAttachments: 20180613 Basin A pH 7.9 after dosing.JPG

20180613 Basin B pH 8.2 after dosing.JPG 20180613 Basin A Turb 1.30.jpg 20180613 Basin B Turb 1.14.jpg 20180613 DEWATERING PERMIT EVIDENCE.pdf 1. ENV Risk Cooling Medium Water WDL211 Discharge signed.pdf 2. Nalco 77352.pdf 3. Nalprep 8349.pdf 4. 602182-W_report.pdf 5. WDL211 MASTER TARP_080518 with Cooling Medium testing.xlsm 6. DV Report_WDL211_080518.pdf 7. Field Records_Combined.pdf 8. Lab Reports_596232 AOC Basin A.pdf 9. 602182_COC.PDF 10. 602182_sample_receipt_coc.pdf 11. 601701_COC.PDF 12. 601701_sample_receipt_coc.pdf 13. 601701-W_report.pdf 15. 597184_COC.PDF



INDRA28-SEP-2018


16. 597184_QS9010_R0 LCQToFMS_GREENCAP_597184-W.PDF 17. 130618_Field Records.pdf 18. 602849_COC.pdf 19. 602849-W-V2_report.pdf 20. ES1817164_0_COA.pdf 21. ES1817164_COC.pdf 14. Results in AOC & Train 1_DV_120618.pdf



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APPENDIX HSample Location Signage

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APPENDIX INon-Compliance Notifications

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Chris Gamble

From: Jane Orr <[email protected]> on behalf of Pollution NTEPA <[email protected]>

Sent: Friday, 10 November 2017 7:44 AMTo: Shoanne LabowitchCc: Leonie Cooper; Waste NTEPA; Pollution NTEPASubject: (PRL6730) RE: WDL 211-4 Notification of Non-Compliance - median Total

Phosphate exceedance

Hi Shoanne Thank you for your notification. No further action is required, apart from including this in annual reporting. For your records the identification number for this report is PRL6730. In future, please could you also send all emails relating to WDL211-4 to [email protected] ([email protected] also goes to the same account). Regards Jane Jane Orr | Senior Environmental Officer | Environmental Operations Environment Division | Department of Environment and Natural Resources

Providing services for the Northern Territory Environment Protection Authority

www.ntepa.nt.gov.au Level 1, Arnhemica House, 16 Parap Road, Parap, NT 0820 GPO Box 3675, Darwin NT 0801 p: (08) 8924 4049 (direct) or (08) 8924 4218 | f: (08) 8924 4053 e: [email protected] | www.nt.gov.au Please consider the environment before printing this email. The information in this email is intended solely for the addressee named. It may contain legally privileged or confidential information that is subject to copyright. Use or transmittal of the information in this email other than for authorised NT Government business purposes may constitute misconduct under the NT Public Sector Code of Conduct and could potentially be an offence under the NT Criminal Code. If you are not the intended recipient you must not use, disclose, copy or distribute this communication. Virus scanning is recommended and is the responsibility of the recipient.

From: Shoanne Labowitch [mailto:[email protected]] Sent: Thursday, 9 November 2017 1:33 PM To: Pollution NTEPA Cc: Snyman VanStraaten; Kresho Zic; Anthony Black Subject: WDL 211-4 Notification of Non-Compliance - median Total Phosphate exceedance Good afternoon, In accordance with the reporting requirements under WDL 211-4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a median mixing zone Total Phosphate (TP) exceedance (100 µg/L) that was recorded on the 30th October 2017 during monitoring of the MOF mixing zone locations, which exceeded the trigger criteria by more than two times. The Phosphate Total (as P) concentration recorded at the upstream reference location (HYDRO-NORTH, based on an incoming tide) did not exceed the trigger criteria. JKC became aware of the exceedance on the 8th November, 2017, following reporting by its Environmental Monitoring Subcontractor. Details of the exceedances, detected during the surface water monitoring sampling event are outlined below:

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• 30th Oct, 2017 - A median exceedance of 100 µg/L for TP was detected at the MOF mixing zone monitoring locations for authorised discharge location DL2, as defined in Table 3 of WDL 211-4, a value that exceeded the trigger value by more than two times. • Exceedances of the TP trigger value were not detected at the upstream reference site, with a value of 17 µg/L , nor at the downstream site, with a value of 23 µg/L. • The surface water sampling was undertaken on 30th October, 2017 at 11:58AM, during an incoming tidal phase with a 0.75 m amplitude [neap tide]. • Sampling of the C600 basin, which was undertaken on the 26th October 2017, prior to discharge, demonstrated a recorded value of 160 µg P/L, which following dilution through the diffuser [minimum 80 fold], is not sufficiently high enough to result in the concentrations recorded at the mixing zone monitoring locations. • The lack of TP exceedance at the downstream site does not align with a plume source signature coming from the diffuser. JKC has prepared the control chart (e.g. section 6.4.3.3, of the ANZECC monitoring and reporting guidelines), which compares the TP median exceedance with the long term 80th percentile for the wet season reference site data collect from the EIMP. The reference data has been collected from the four EIMP reference sites and the upstream reference sites from the WDL211-4 and the WDL192-3 monitoring programs.

The TP mixing zone exceedance data exceeds the 80th percentile for the reference sites. The exceedance of the 80th percentile is a trigger for further investigation. Further investigation Construction water sampling was undertaken prior to discharge via the MOF outfall, with the most recent sample collected on the 26th October 2017. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (Document No. L290-AH-PLN-10231). The sampling returned a TP value of 160 µg/L, which after 80 fold dilution through the outfall is not sufficient to result in the concentrations detected at the mixing zone monitoring locations. Therefore, the potential for environmental harm to the receiving environment receptors (water column, soft bottom benthic) associated with the discharge is Low. It is noted that the 80th percentile is calculated using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally, whereby the 80th percentile warns us when we are approaching the maximum values expected at the site. Further review of the chart shows that the reference sites also exhibited higher TP concentrations at times during the 2016/17 wet season. The TP exceedances detected during sampling of

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the mixing zone are considered to represent seasonal harbour based influences and as such were not associated with the WDL211-4 discharges. The median exceedance observed at the mixing zone monitoring locations is not believed to be attributable to the MOF discharge event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters with no associated risk of environmental harm. For further information, please contact the JKC Approvals Manager Kresho Zic, on 08 8931 8986 Kind regards Shoanne Labowitch Government Approvals Advisor Ichthys Project JKC Australia LNG Pty Ltd Level 6, 66 Smith Street, Darwin City, NT. 0801. PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected] This e-mail, including any attached files, may contain confidential and privileged information for the sole use of the intended recipient. Any review, use, distribution, or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive information for the intended recipient), please contact the sender by reply e-mail and delete all copies of this message.

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Chris Gamble

From: Shoanne Labowitch <[email protected]>Sent: Wednesday, 25 July 2018 4:52 PMTo: Waste NTEPA; Kresho ZicCc: Anthony BlackSubject: RE: WDL 211-4: Incident Notification - Unauthorised Discharge 06 July, 2018

Good afternoon Sally-anne, As per your email below, JKC hereby provides further information to clarify its actions and the notification sent to NT EPA on the 11th July, 2018, referred to as PRL7251. We have focussed the investigation report on Condition 18 – plant and equipment, and addressed Condition 38 reporting as follows: Condition 38.1: When the non-compliance was detected and by whom The leak from the MOF line was detected on the 6th July 2018 at 11:45 AM by JKC engineer Stephen Mellier. This was reported to NT EPA on the 11 July 2018. The reason for the delay in notification (5 days) was that the event was initially reported to our Client, INPEX on Friday 6th July, however there was some confusion as to the applicable approval under which the incident needed to be reported ( CEMP or WDL211). A decision was made on Tuesday that it was to be WDL 211-4 and JKC’s Lead Environmental Advisor responsible for the environmental assessment was sick that day. As a consequence, reporting to NT EPA occurred on Wednesday 11th July 2018. Controls have been put into place to prevent this reoccurring in that any WDL 211-4 equipment fault resulting in a discharge to Darwin Harbour will be reported under WDL 211-4 within 24 hours and in accordance with the licence conditions. Condition 38.2: The date and time of the non-compliance The MOF outfall line leak occurred during the day of the Friday 6th July 2018 and was detected at 11:45 AM. Condition 38.3: The actual and potential causes and contributing factors to the non-compliance The MOF discharge line coupling has come loose between the lay flat section and the solid pipe that goes down to the end of the MOF and the diffuser. The loose connection allowed for passive discharge of water into Darwin Harbour. Condition 38.4: The risk of environmental harm arising from the non-compliance JKC have calculated the volume released from the pipe and has determined it to be approximately 20KL of water that was charged in the section of lay flat pipe and that subsequently entered Darwin Harbour. A review of dewatering permits back to 16 June, 2018 have identified 4 firewater / potable water deluge permits, which totalled 274KL, and are associated with the water present in the pipework at the time of the non-compliance. As such, the water was considered to be uncontaminated potable water with an associated low risk when it was released into Darwin Harbour. Greencap were mobilised for precautionary sampling with analyses for the WDL 211-4 suite applicable to authorised discharge location DL1 [nutrients, metals and hydrocarbons] and the results are presented below. All other parameters did not exceed the water quality criteria. Environmental Investigation Results are available from the leak water and the 3 response sampling locations sampled 6th July 2018. The leak water from the MOF pipe was compared to the approved criteria for discharge via the regulating drain (DL1) and the harbour sites were compared to receiving environment water quality criteria as per WDL 211-4 in Table 1:

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Table 1: exceedance data comparison table Environmental Assessment of the results include:

- The leak water spill released from the MOF line contained exceedances of NOx, FRP, TSS and Zinc for authorised discharge Location DL1, and is a trigger of WDL 211-4 Condition 21.1.

- Only one analyte, TSS, was also exceeded in the receiving environment sampling. However, the concentration of TSS was lower in the leak water than in the receiving environment and therefore excludes the discharge as being the source of the TSS exceedance observed in the receiving environment.

- TP in the leak water did not exceed the approved criteria in WDL 211-4 and following 1:5 dilution that occurred as the discharge was released over the rock armour and into Darwin Harbour, would not be sufficient to be the source of the TP in the receiving environment.

- To put these results into context, JKC has prepared the control charts (e.g. section 6.4.3.3, of the ANZECC monitoring and reporting guidelines), which compares the receiving environment TSS and TP exceedances with the long term 80th percentile for the dry season reference site data collect from the EIMP. The reference data has been collected from the four EIMP reference sites and the upstream reference sites from the WDL 211-4 and the WDL 192-3 monitoring programs [see below figures].

- Based on the receiving environment results there were slight exceedances of the 80 percentile for NOx [1 location] and for TSS, TP and As [all 3 locations]. It is noted that the 80th percentile is calculated using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally, whereby the 80th percentile warns us when we are approaching the maximum seasonal values previously seen at the reference sites. Further review of the chart shows that the reference sites also exhibited NOx, TSS, TP and As concentrations above the 80th percentile value at times during the previous 2016/17/18 wet season and also during the current 2018 dry season.

- The spill of 20KL was of a limited duration and would have been substantially diluted by the diurnal tides that have occurred since the event.

- Therefore, the potential for environmental harm to the receiving environment receptors (water column, soft bottom benthic) associated with the discharge is negligible. The exceedances observed at the mixing zone monitoring locations are not believed to be attributable to the MOF spill event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters associated with Darwin Harbour seasonal cycles, with no associated risk of environmental harm.

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Figure 1- Receiving environment NOX exceedances versus the 80th percentile of reference locations

Figure 2- Receiving environment TP exceedances versus the 80th percentile of reference locations

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Figure 3- Receiving environment TSS exceedances versus the 80th percentile of reference locations

Figure 4- Receiving environment TSS exceedances versus the 80th percentile of reference locations Condition 38.5: The actions(s) that have or will be taken to mitigate any environmental harm arising from the non-compliance JKCs Environmental Monitoring Subcontractor have been mobilised to collect a sample from the leaked water and to undertake response sampling at 3 locations in proximity to where the escaped water entered Darwin Harbour and the non-compliance has been shown to have a negligible risk for environmental harm. The coupling has been realigned and leak has ceased with no ongoing unauthorised discharge occurring. Condition 38.6: Corrective actions that have or will be undertaken to ensure the non-compliance does not reoccur Reporting to NT EPA occurred on Wed 11th July 2018- 5 days after the event. Controls have been put into place to prevent this reoccurring in that any WDL 211-4 equipment fault resulting in a discharge to Darwin Harbour will be reported under WDL 211-4 automatically and within 24 hours. The coupling misalignment was caused partially - By degradation of sand bags that were in place to support and elevate the MOF outfall pipe at the junction of lay flat section and poly pipe section, which result in the pipe rolling over causing the cam lock to unlock. - No split pins were in place to prevent the lock from dislodging. The sand bags have been replaced and a cam lock fitted with a split pin as the key controls so this cannot reoccur.

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The team managing the MOF pumping have also included an additional control to undertake inspections of the line to check for physical issues like the above as part of their preventative maintenance operations. Condition 38.7: If no action was taken, why no action was taken Action was taken and is considered resolved. Condition 38.9: A date when an incident investigation or incident closure report, if requested by the administrating agency, will be submitted to the agency. The previous email from NT EPA outlines that JKC shall prepare a response by 25th July 2018. This communication provides the detailed environment investigation and assessment and fulfils the requirements of the closure report. We trust this provides a sufficient level of detail for the event to be closed out. If you have anything further, please contact the JKC Environment Manager Kresho Zic, on 08 8931 8986. Kind regards Shoanne Labowitch Government Approvals Manager Ichthys Project JKC Australia LNG Pty Ltd T300, 130 The Esplanade, Darwin, NT, 0800 PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected] From: Sally-anne Orchard [mailto:[email protected]] On Behalf Of Waste NTEPA Sent: Wednesday, 11 July 2018 2:42 PM To: Kresho Zic <[email protected]> Cc: Anthony Black <[email protected]>; Shoanne Labowitch <[email protected]>; Waste NTEPA <[email protected]> Subject: RE: WDL 211-4: Incident Notification - Unauthorised Discharge 06 July, 2018 Hi Kresho, Thanks for your time on the phone today. As discussed, could you please provide an investigation report detailing information relevant to condition 38 of WDL211-4. In the investigation report, please also outline the results from your responsive sampling event including an environmental risk assessment. Please refer to trigger values within WDL211-4. Could you also please outline, with regard to condition 38.3 a response relative to condition 18 –equipment related to the matter. Please also outline in the investigation report, the reason for the delay in notification (5 days) and corrective actions that will be undertaken to ensure significant delays in non-compliance notification reporting do not reoccur. Please provide the report within 10 business days, by 25 July 2018. For your records, the non-compliance notification has been recorded in our database as PRL7251. Regards,

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Sally-Anne Sally-Anne Orchard | Environmental Officer I Environmental Authorisations Environment Division | Department of Environment and Natural Resources p...(08) 8924 4028I f... (08) 8924 4053 e [email protected] I www.ntepa.nt.gov.au Providing services for the Northern Territory Environment Protection Authority


Please consider the environment before printing this email. Use or transmittal of the information in this email other than for authorised NT Government business purposes may constitute misconduct under the NT Public Sector Code of Conduct and could potentially be an offence under the NT Criminal Code. The information contained in this message and any attachments may be subject to legal privilege, public interest or legal profession privilege. If you are not the intended recipient, any use, disclosure or copying of this message or any attachments is unauthorised. If you have received this document in error, please advise the sender. No representation or warranty is given that attached files are free from viruses or other defects. The recipient assumes all responsibility for any loss or damage resulting directly or indirectly from the use of any attached files. From: Shoanne Labowitch [mailto:[email protected]] Sent: Wednesday, 11 July 2018 11:31 AM To: Waste NTEPA Cc: Anthony Black; Kresho Zic Subject: WDL 211-4: Incident Notification - Unauthorised Discharge 06 July, 2018 Good morning, In accordance with WDL 211-4 Condition 36 to Condition 38, JKC Australia LNG Pty Ltd (JKC) hereby informs NT EPA concerning a non-compliance with WDL 211-4 Condition 19 and Condition 21, regarding the passive discharge of potable water from a loose pipe coupling associated with the equipment used to conduct the MOF discharge activity approved under WDL 211-4. The non-compliance occurred on Friday 06 July, 2018. Information available is as follows: The MOF discharge line coupling has come loose between the lay flat section and the solid pipe that goes down to the end of the MOF and the diffuser. The loose connection allowed for passive discharge of water into Darwin Harbour:

• JKC have calculated the volume released from the pipe and has determined it to be approximately 20KL of water that was charged in the section of lay flat pipe and that subsequently entered Darwin Harbour.

• There was not any active discharge under WDL 211-4 occurring at the time of the event. • A review of recent dewatering permits back to 16 June, 2018 have identified 4 firewater / potable water

deluge permits, which totalled 274KL, and are associated with the water present in the pipework at the time of the non-compliance,

Results are available from 03 June, 2018 for samples collected from the most recent sampling event for the characterisation of water contained within the C600 holding basin. When the data collected is compared with the Receiving Environment Water Quality Monitoring Trigger Values, a number of exceedances were observed that are applicable to authorised discharge location, DL1 (Regulating Reservoir), and are described below: - Ammonia (57 µg/L) – TV 47 µg/L - Zinc (28 µg/L) – TV 23.9 µg/L

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• JKCs Environmental Monitoring Subcontractor have been mobilised to collect a sample from the leaked

water and to undertake response sampling at 3 locations in proximity to where the escaped water entered Darwin Harbour, the results from this sampling are due next week,

• The coupling has been realigned and leak has ceased with no ongoing unauthorised discharge occurring, • There was a 2.94m tidal variance for the next cycle on the day of the non-compliance – outgoing.

For further information, please contact the JKC Environmental Manager Kresho Zic, on 8931 8986 Kind regards Shoanne Labowitch Government Approvals Advisor Ichthys Project JKC Australia LNG Pty Ltd T300, 130 The Esplanade, Darwin, NT, 0800 PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected] This e-mail, including any attached files, may contain confidential and privileged information for the sole use of the intended recipient. Any review, use, distribution, or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive information for the intended recipient), please contact the sender by reply e-mail and delete all copies of this message.

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Chris Gamble

From: Sally-anne Orchard <[email protected]> on behalf of Waste NTEPA <[email protected]>

Sent: Wednesday, 3 January 2018 12:09 PMTo: Shoanne LabowitchCc: Snyman VanStraaten; Kresho Zic; Anthony BlackSubject: RE: WDL 211-4 Notification of Non-Compliance - median Oxides of Nitrogen

exceedance

Hi Shoanne Thank you for your notification. No further action is required, apart from including this in annual reporting. For your records the identification number for this report is PRL6837. As a general note, I’ve interpreted references to 18th October 2017 and Total Phosphorous as typing errors and have logged the exceedances as NOx occurring in December 2017. Please advise if this is incorrect. Sally-Anne Sally-Anne Orchard | Environmental Officer I Environmental Authorisations Environment Division | Department of Environment and Natural Resources p...(08) 8924 4028I f... (08) 8924 4053 e [email protected] I www.ntepa.nt.gov.au Providing services for the Northern Territory Environment Protection Authority


Please consider the environment before printing this email. Use or transmittal of the information in this email other than for authorised NT Government business purposes may constitute misconduct under the NT Public Sector Code of Conduct and could potentially be an offence under the NT Criminal Code. The information contained in this message and any attachments may be subject to legal privilege, public interest or legal profession privilege. If you are not the intended recipient, any use, disclosure or copying of this message or any attachments is unauthorised. If you have received this document in error, please advise the sender. No representation or warranty is given that attached files are free from viruses or other defects. The recipient assumes all responsibility for any loss or damage resulting directly or indirectly from the use of any attached files. From: Shoanne Labowitch [mailto:[email protected]] Sent: Wednesday, 3 January 2018 8:51 AM To: Waste NTEPA Cc: Snyman VanStraaten; Kresho Zic; Anthony Black Subject: WDL 211-4 Notification of Non-Compliance - median Oxides of Nitrogen exceedance Good morning, In accordance with the reporting requirements under WDL 211-4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a median mixing zone exceedance of Oxides of Nitrogen (NOx) (57 µg/L) that was recorded on the 18th of December, 2017 during monitoring of the MOF mixing zone locations, which exceeded the trigger criteria of 20 µg/L by more than two times. The NOx concentration

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recorded at the upstream reference location (HYDRO-SOUTH, based on an outgoing tide) did not exceed the trigger criteria. JKC became aware of the exceedance on the 2nd January, 2017, following reporting by its Environmental Monitoring Subcontractor. Details of the exceedances, detected during the surface water monitoring sampling event are outlined below: • 18th Oct, 2017 - A median exceedance of 57 µg/L for NOx was detected at the MOF mixing zone monitoring

locations for authorised discharge location DL2, as defined in Table 3 of WDL 211-4, a value that exceeded the trigger value by more than two times.

• Exceedances of the NOx trigger value were not detected at the upstream reference site, with a value of 10 µg/L , nor at the downstream site, with a value of 7 µg/L.

• The surface water sampling was undertaken on 18th December, 2017 at 10:43AM, during an outgoing tidal phase with a 5.16 m amplitude.

• Sampling of the C600 basin, which was undertaken on the 11th December, 2017, prior to discharge, demonstrated a NOx value of 22 µg/L, which following dilution through the diffuser [minimum 80 fold], is not sufficiently high enough to result in the concentrations recorded at the mixing zone monitoring locations.

• The lack of NOx exceedance at the downstream site does not align with a plume source signature coming from the diffuser.

JKC has prepared the control chart (e.g. section 6.4.3.3, of the ANZECC monitoring and reporting guidelines), which compares the TP median exceedance with the long term 80th percentile for the wet season reference site data collect from the EIMP. The reference data has been collected from the four EIMP reference sites and the upstream reference sites from the WDL211-4 and the WDL192-3 monitoring programs.

The NOx mixing zone exceedance data exceeds the 80th percentile for the reference sites. The exceedance of the 80th percentile is a trigger for further investigation. Further investigation Construction water sampling was undertaken prior to discharge via the MOF outfall, with the most recent sample collected on the 11th December, 2017. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting

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Documentation (Document No. L290-AH-PLN-10231). The sampling returned a TP value of 22 µg/L, which after 80 fold dilution through the outfall is not sufficient to result in the concentrations detected at the mixing zone monitoring locations. Therefore, the potential for environmental harm to the receiving environment receptors (water column, soft bottom benthic) associated with the discharge is Low. It is noted that the 80th percentile is calculated using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally, whereby the 80th percentile warns us when we are approaching the maximum seasonal values previously seen at the reference sites. Further review of the chart shows that the reference sites also exhibited NOx concentrations above the 80 percentile value at times during the previous 2016/17 wet season and also during the current 2017/18 wet season. The NOx exceedances detected during sampling of the mixing zone are considered to represent seasonal harbour based influences and were not associated with the WDL211-4 discharges. The median exceedance observed at the mixing zone monitoring locations is not believed to be attributable to the MOF discharge event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters associated with Darwin Harbour seasonal cycles, with no associated risk of environmental harm. For further information, please contact the JKC Environment Manager Kresho Zic, on 08 8931 8986. Kind regards Shoanne Labowitch Government Approvals Advisor Ichthys Project JKC Australia LNG Pty Ltd Level 6, 66 Smith Street, Darwin City, NT. 0801. PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected] This e-mail, including any attached files, may contain confidential and privileged information for the sole use of the intended recipient. Any review, use, distribution, or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive information for the intended recipient), please contact the sender by reply e-mail and delete all copies of this message.

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Chris Gamble

From: Jane Orr <[email protected]> on behalf of Pollution NTEPA <[email protected]>

Sent: Friday, 15 December 2017 2:07 PMTo: Shoanne LabowitchCc: Patrick Doran; Waste NTEPASubject: RE: WDL 211-4 Notification of Non-Compliance - median Total Phosphate

exceedance

Hi Shoanne Thank you for notification. In future, send all emails related to WDL211 and WDL192 to [email protected] as specified in the licences (c33 for WDL192-3 and c37 for WDL211-4). Regards Jane Jane Orr | Senior Environmental Officer | Environmental Operations Environment Division | Department of Environment and Natural Resources Providing services for the Northern Territory Environment Protection Authority

www.ntepa.nt.gov.au Level 1, Arnhemica House, 16 Parap Road, Parap, NT 0820 GPO Box 3675, Darwin NT 0801 p: (08) 8924 4049 (direct) or (08) 8924 4218 | f: (08) 8924 4053 e: [email protected] | www.nt.gov.au Please consider the environment before printing this email. The information in this email is intended solely for the addressee named. It may contain legally privileged or confidential information that is subject to copyright. Use or transmittal of the information in this email other than for authorised NT Government business purposes may constitute misconduct under the NT Public Sector Code of Conduct and could potentially be an offence under the NT Criminal Code. If you are not the intended recipient you must not use, disclose, copy or distribute this communication. Virus scanning is recommended and is the responsibility of the recipient. From: Shoanne Labowitch [mailto:[email protected]] Sent: Friday, 15 December 2017 12:50 PM To: Pollution NTEPA Cc: Snyman VanStraaten; Anthony Black; Kresho Zic Subject: WDL 211-4 Notification of Non-Compliance - median Total Phosphate exceedance Good afternoon, In accordance with the reporting requirements under WDL 211-4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a median mixing zone for Chlorophyll-a, which was more than twice the 4 µg/L trigger value (8.9 µg/L) on 27 November, 2017 which exceeded the trigger criteria by more than double. The Chlorophyll-a concentration recorded at the upstream reference location (HYDRO-SOUTH, based on an incoming tide) did not exceed the trigger criteria. The exceedances were detected during surface water monitoring activities undertaken on 27 November, 2017. Monitoring was associated with the discharge of construction water from the holding basin at Area C600 at Bladin Point. JKC received the sampling results information from its Environmental Monitoring Subcontractor yesterday: 14 December, 2017. Details of the exceedance detected during the surface water monitoring sampling event is outlined below:

• Exceedances of 8.9, 12 and 5.3 µg/L for Chlorophyll-a was detected at MOF Monitoring Site HYDRO-01, HYDRO-02 and HYDRO-03, respectively for authorised discharge location DL2, as defined in Table 3 of WDL

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211-4. The exceedance was not detected at the upstream monitoring site with a recorded value of <5 µg/L, but was detected at the downstream monitoring sites, with a value of 9.3 µg/L

• The surface water sampling was undertaken on Monday 27 November, 2017, at 13:25-13:57 for the three mixing zone sites, during an outgoing tidal phase with a 1.63 m amplitude.

• End of pipe water sampling was undertaken on 23 November, 2017 prior to discharge via the MOF outfall. End of pipe testing did not include Chlorophyll-a as the construction water as this water was sourced from a combination of potable water (deluge testing and wall wash-down) and rainwater from sumps at site and which have low potential for containing algae.

• The previous discharge occurred on the 23 November, 2017. The trigger for this discharge (water reaching 80% capacity) occurred on the 27 November, 2017 which indicates that the short residence time of the water in the C600 basin is not sufficient to have sustained significant algal growth.

• The potential for the discharged water to be the source of the Chlorophyll-a exceedance recorded at the mixing zone monitoring location is therefore considered to be Low.

Kindly contact Dr. Anthony Black on 8931 8190, for further information. Kind regards Shoanne Labowitch Government Approvals Advisor Ichthys Project JKC Australia LNG Pty Ltd Level 6, 66 Smith Street, Darwin City, NT. 0801. PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected] This e-mail, including any attached files, may contain confidential and privileged information for the sole use of the intended recipient. Any review, use, distribution, or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive information for the intended recipient), please contact the sender by reply e-mail and delete all copies of this message.

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Chris Gamble

From: Shoanne Labowitch <[email protected]>Sent: Monday, 27 August 2018 4:21 PMTo: Waste NTEPA; Kresho ZicCc: Anthony BlackSubject: RE: WDL 211-4 Notification of Non-Compliance with Trigger Values for NOx - 19

July 2018

Good afternoon Sally-anne, I will respond on Kresho’s behalf, Yes, there are two different aspects to note concerning the observed exceedance of Oxides of Nitrogen: - The first aspect is the heterogeneity of the sample when comparing the reportable exceedance with the greater 80th percentile dataset collected for the EIMP. For the EIMP data, elevated NOx and nutrient values in the harbour are commonly recorded. This is a relatively common occurrence and is sometimes observed in the samples collected from the mixing zone locations, as was the case on this occasion. - The second aspect is that the physico-chemical data (i.e. EC and turbidity etc.) measured at the mixing zone sampling locations were observed to be very stable during the sampling event. This suggests that any influence from a freshwater plume discharged from the MOF during the discharge event has not occurred, and that the diffuser is working as per the design and resulting in sufficient dilution of the discharged water. Furthermore, there were no observed sheens, scums, plumes etc. noted during the field observations that were taken during the sampling event. Kind regards Shoanne Labowitch Government Approvals Manager Ichthys Project JKC Australia LNG Pty Ltd T300, 130 The Esplanade, Darwin, NT, 0800 PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected] From: Sally-anne Orchard [mailto:[email protected]] On Behalf Of Waste NTEPA Sent: Wednesday, 22 August 2018 10:03 AM To: Kresho Zic <[email protected]> Cc: Shoanne Labowitch <[email protected]>; Anthony Black <[email protected]> Subject: RE: WDL 211-4 Notification of Non-Compliance with Trigger Values for NOx - 19 July 2018 Hi Kresho, I am hoping to enquire about the non-compliance further. In relation to point 6 below, were there any field observations observed or significant variations in physico-chemical parameters measured during the sample event, in the sample matrix that would further support this conclusion? I note that in terms of seasonal cycles, NOx is typically elevated in the wet season. Regards, Sally-Anne Orchard

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Environmental Officer Environmental Authorisations Department of Environment and Natural Resources Northern Territory Government Providing services for the

www.ntepa.nt.gov.au Level 1, Arnhemica House, 16 Parap Road, Parap NT 0820 GPO Box 3675, Darwin NT 0801 P: 8924 4028 E: [email protected] W: www.denr.nt.gov.au

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Use or transmittal of the information in this email other than for authorised NT Government business purposes may constitute misconduct under the NT Public Sector Code of Conduct and could potentially be an offence under the NT Criminal Code. The information in this e-mail is intended solely for the addressee named. It may contain legally privileged or confidential information that is subject to copyright. If you are not the intended recipient you must not use, disclose copy or distribute this communication. If you have received this message in error, please delete the e-mail and notify the sender. No representation is made that this e-mail is free of viruses. Virus scanning is recommended and is the responsibility of the recipient From: Shoanne Labowitch <[email protected]> Sent: Tuesday, 21 August 2018 9:35 AM To: Waste NTEPA <[email protected]> Cc: Anthony Black <[email protected]>; Kresho Zic <[email protected]> Subject: WDL 211-4 Notification of Non-Compliance with Trigger Values for NOx - 19 July 2018 Good afternoon, In accordance with the reporting requirements under WDL 211-4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a mixing zone median exceedance of the trigger value for Oxides of Nitrogen (NOx), which was more than double the 20 µg/L trigger value, and was not also present at the upstream reference site, as per Appendix 3 of WDL 211-4. The median exceedance was detected during surface water monitoring activities undertaken on 19th July, 2018. Monitoring was associated with the discharge of AOC waters from the C600 holding basin. JKC received the sampling results information yesterday, 20th August, 2017, from its Environmental Monitoring Subcontractor following compilation of the dataset and completion of quality assurance reporting. JKC has requested Subcontractor efforts to ensure sampling results are provided in a more expedient manner going forward. Details of the exceedance detected during the surface water monitoring sampling event are outlined below:




3. End of pipe sampling was undertaken on 17th July, 2018, 2 days prior to discharge via the MOF outfall. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (Document No. L290-AH-

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PLN-10231). The sampling returned an Oxides of Nitrogen value of 710 µg/L, which following dilution of 80 fold, is not sufficient to result in the observed median exceedance at the mixing zone monitoring locations.







Further investigation Construction water sampling was undertaken prior to discharge via the MOF outfall, with the most recent sample collected on the 17th July, 2018. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (Document No. L290-AH-PLN-10231). The sampling returned an Oxides of Nitrogen value of 710 µg/L, which following dilution of 80 fold, is not sufficient to result in the observed median exceedance at the mixing zone monitoring locations. Further, this sampling event forms one of a series of monitoring events for the discharge which ran from 17th July through to 31st July 2018. There were no other median exceedances of NOx in the discharge prior to and after the reportable event, which demonstrates that the exceedance is not related to the discharge

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event. Therefore, the potential for the NOx exceedance to be attributed to the discharge, and potential for environmental harm to the receiving environment receptors (water column, soft bottom benthic) associated with the discharge is negligible.

It is noted that the 80th percentile is calculated using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally, whereby the 80th percentile warns us when we are approaching the maximum seasonal values previously seen at the reference sites. Further review of the chart shows that the reference sites also exhibited NOx concentrations above the 80th percentile value at times during the previous 2016/17 wet season and also during the current 2017/18 wet season. The NOx exceedances detected during sampling of the mixing zone are considered to represent seasonal harbour based influences and were not associated with the WDL211-4 discharges. The median exceedance observed at the mixing zone monitoring locations is not believed to be attributable to the MOF discharge event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters associated with Darwin Harbour seasonal cycles, with no associated risk of environmental harm. For further information, please contact the JKC Environment Manager Kresho Zic, on 08 8931 8986. Kind regards Shoanne Labowitch Government Approvals Manager Ichthys Project JKC Australia LNG Pty Ltd T300, 130 The Esplanade, Darwin, NT, 0800 PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected] This e-mail, including any attached files, may contain confidential and privileged information for the sole use of the intended recipient. Any review, use, distribution, or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive information for the intended recipient), please contact the sender by reply e-mail and delete all copies of this message.

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Chris Gamble

From: Shoanne Labowitch <[email protected]>Sent: Tuesday, 8 May 2018 4:18 PMTo: '[email protected]'Cc: Snyman VanStraaten; Kresho Zic; Anthony BlackSubject: WDL 211-4 Notification of Non-Compliance - median Cu TV exceedance 14 April

2018

Good afternoon, In accordance with the reporting requirements under WDL 211-4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a median mixing zone exceedance of Copper (Cu) (4 µg/L) that was recorded on the 14th April, 2018 during monitoring of the MOF mixing zone locations, which exceeded the trigger criteria of 1.3 µg/L by more than two times. The Cu concentration recorded at the upstream reference location (HYDRO-SOUTH, based on an outgoing tide) did not exceed the trigger criteria (1 µg/L). JKC became aware of the exceedance on the 8th May, 2018, following reporting by its Environmental Monitoring Subcontractor, who has indicated that the data (field QA/QC, COC and laboratory QA/QC) has been assessed as valid and can be relied upon by Contractor (JKC) and Company (INPEX) for approval compliance purposes. Details of the exceedances, detected during the surface water monitoring sampling event are outlined below: • 14th April, 2018 - A median exceedance of 4 µg/L for Cu was detected at the MOF mixing zone monitoring


• Exceedances of the Cu trigger value were not detected at the upstream reference site, with a value of 1 µg/L , however an exceedance was detected at the downstream site, with a value of 2 µg/L.

• The surface water sampling was undertaken on 14th April, 2018 at 09:53AM, during an outgoing tidal phase with a 3.79 m amplitude.

• Sampling of the C600 basin, which was undertaken on the 3rd April, 2018, prior to discharge, demonstrated a Cu value of <1 µg/L which does not exceed the trigger value. The lack of Cu exceedance at the source does not align with a plume source signature coming from the diffuser.

JKC has prepared the control chart (e.g. section 6.4.3.3, of the ANZECC monitoring and reporting guidelines), which compares the Cu median exceedance with the long term 80th percentile for the wet season reference site data collect from the EIMP. The reference data has been collected from the four EIMP reference sites and the upstream reference sites from the WDL211-4 and the WDL192-3 monitoring programs.

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The Cu mixing zone exceedance data exceeds the 80th percentile for the reference sites. The exceedance of the 80th percentile is a trigger for further investigation. Further investigation Construction water sampling was undertaken prior to discharge via the MOF outfall, with the most recent sample collected on the 3rd April, 2018. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (Document No. L290-AH-PLN-10231). The sampling returned a Cu value of <1 µg/L, which does not exceed the TV and after 80 fold dilution through the outfall is not sufficient to result in the concentrations detected at the mixing zone monitoring locations. Therefore, the potential for environmental harm to the receiving environment receptors (water column, soft bottom benthic) associated with the discharge is negligible. It is noted that the 80th percentile is calculated using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally, whereby the 80th percentile warns us when we are approaching the maximum seasonal values previously seen at the reference sites. Further review of the chart shows that the reference sites also exhibited Cu concentrations above the 80th percentile value at times during the previous 2016/17 wet season and also during the current 2017/18 wet season. The Cu exceedances detected during sampling of the mixing zone are considered to represent seasonal harbour based influences and were not associated with the WDL211-4 discharges. The median exceedance observed at the mixing zone monitoring locations is not believed to be attributable to the MOF discharge event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters associated with Darwin Harbour seasonal cycles, with no associated risk of environmental harm. For further information, please contact the JKC Environment Manager Kresho Zic, on 08 8931 8986. Kind regards

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Shoanne Labowitch Government Approvals Advisor Ichthys Project JKC Australia LNG Pty Ltd Level 6, 66 Smith Street, Darwin City, NT. 0801. PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected]

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Chris Gamble

From: Shoanne Labowitch <[email protected]>Sent: Wednesday, 3 January 2018 8:52 AMTo: [email protected]: Snyman VanStraaten; Kresho Zic; Anthony BlackSubject: WDL 211-4 Notification of Non-Compliance - median Oxides of Nitrogen

exceedance

Good morning, In accordance with the reporting requirements under WDL 211-4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a median mixing zone exceedance of Oxides of Nitrogen (NOx) (57 µg/L) that was recorded on the 18th of December, 2017 during monitoring of the MOF mixing zone locations, which exceeded the trigger criteria of 20 µg/L by more than two times. The NOx concentration recorded at the upstream reference location (HYDRO-SOUTH, based on an outgoing tide) did not exceed the trigger criteria. JKC became aware of the exceedance on the 2nd January, 2017, following reporting by its Environmental Monitoring Subcontractor. Details of the exceedances, detected during the surface water monitoring sampling event are outlined below: • 18th Oct, 2017 - A median exceedance of 57 µg/L for NOx was detected at the MOF mixing zone monitoring


• Exceedances of the NOx trigger value were not detected at the upstream reference site, with a value of 10 µg/L , nor at the downstream site, with a value of 7 µg/L.

• The surface water sampling was undertaken on 18th December, 2017 at 10:43AM, during an outgoing tidal phase with a 5.16 m amplitude.

• Sampling of the C600 basin, which was undertaken on the 11th December, 2017, prior to discharge, demonstrated a NOx value of 22 µg/L, which following dilution through the diffuser [minimum 80 fold], is not sufficiently high enough to result in the concentrations recorded at the mixing zone monitoring locations.

• The lack of NOx exceedance at the downstream site does not align with a plume source signature coming from the diffuser.

JKC has prepared the control chart (e.g. section 6.4.3.3, of the ANZECC monitoring and reporting guidelines), which compares the TP median exceedance with the long term 80th percentile for the wet season reference site data collect from the EIMP. The reference data has been collected from the four EIMP reference sites and the upstream reference sites from the WDL211-4 and the WDL192-3 monitoring programs.

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The NOx mixing zone exceedance data exceeds the 80th percentile for the reference sites. The exceedance of the 80th percentile is a trigger for further investigation. Further investigation Construction water sampling was undertaken prior to discharge via the MOF outfall, with the most recent sample collected on the 11th December, 2017. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (Document No. L290-AH-PLN-10231). The sampling returned a TP value of 22 µg/L, which after 80 fold dilution through the outfall is not sufficient to result in the concentrations detected at the mixing zone monitoring locations. Therefore, the potential for environmental harm to the receiving environment receptors (water column, soft bottom benthic) associated with the discharge is Low. It is noted that the 80th percentile is calculated using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally, whereby the 80th percentile warns us when we are approaching the maximum seasonal values previously seen at the reference sites. Further review of the chart shows that the reference sites also exhibited NOx concentrations above the 80 percentile value at times during the previous 2016/17 wet season and also during the current 2017/18 wet season. The NOx exceedances detected during sampling of the mixing zone are considered to represent seasonal harbour based influences and were not associated with the WDL211-4 discharges. The median exceedance observed at the mixing zone monitoring locations is not believed to be attributable to the MOF discharge event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters associated with Darwin Harbour seasonal cycles, with no associated risk of environmental harm. For further information, please contact the JKC Environment Manager Kresho Zic, on 08 8931 8986. Kind regards Shoanne Labowitch Government Approvals Advisor

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Ichthys Project JKC Australia LNG Pty Ltd Level 6, 66 Smith Street, Darwin City, NT. 0801. PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected]

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Chris Gamble

From: Shoanne Labowitch <[email protected]>Sent: Friday, 15 December 2017 12:51 PMTo: Pollution NTEPACc: Snyman VanStraaten; Anthony Black; Kresho ZicSubject: WDL 211-4 Notification of Non-Compliance - median Total Phosphate

exceedance

Good afternoon, In accordance with the reporting requirements under WDL 211-4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a median mixing zone for Chlorophyll-a, which was more than twice the 4 µg/L trigger value (8.9 µg/L) on 27 November, 2017 which exceeded the trigger criteria by more than double. The Chlorophyll-a concentration recorded at the upstream reference location (HYDRO-SOUTH, based on an incoming tide) did not exceed the trigger criteria. The exceedances were detected during surface water monitoring activities undertaken on 27 November, 2017. Monitoring was associated with the discharge of construction water from the holding basin at Area C600 at Bladin Point. JKC received the sampling results information from its Environmental Monitoring Subcontractor yesterday: 14 December, 2017. Details of the exceedance detected during the surface water monitoring sampling event is outlined below:

• Exceedances of 8.9, 12 and 5.3 µg/L for Chlorophyll-a was detected at MOF Monitoring Site HYDRO-01, HYDRO-02 and HYDRO-03, respectively for authorised discharge location DL2, as defined in Table 3 of WDL 211-4. The exceedance was not detected at the upstream monitoring site with a recorded value of <5 µg/L, but was detected at the downstream monitoring sites, with a value of 9.3 µg/L

• The surface water sampling was undertaken on Monday 27 November, 2017, at 13:25-13:57 for the three mixing zone sites, during an outgoing tidal phase with a 1.63 m amplitude.

• End of pipe water sampling was undertaken on 23 November, 2017 prior to discharge via the MOF outfall. End of pipe testing did not include Chlorophyll-a as the construction water as this water was sourced from a combination of potable water (deluge testing and wall wash-down) and rainwater from sumps at site and which have low potential for containing algae.

• The previous discharge occurred on the 23 November, 2017. The trigger for this discharge (water reaching 80% capacity) occurred on the 27 November, 2017 which indicates that the short residence time of the water in the C600 basin is not sufficient to have sustained significant algal growth.

• The potential for the discharged water to be the source of the Chlorophyll-a exceedance recorded at the mixing zone monitoring location is therefore considered to be Low.

Kindly contact Dr. Anthony Black on 8931 8190, for further information. Kind regards Shoanne Labowitch Government Approvals Advisor Ichthys Project JKC Australia LNG Pty Ltd Level 6, 66 Smith Street, Darwin City, NT. 0801. PO Box 2079, Darwin, NT. 0801

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Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected]

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Chris Gamble

From: Shoanne Labowitch <[email protected]>Sent: Thursday, 9 November 2017 1:35 PMTo: Pollution NTEPACc: Snyman VanStraaten; Kresho Zic; Anthony BlackSubject: WDL 211-4 Notification of Non-Compliance - median Total Phosphate

exceedance

Good afternoon, In accordance with the reporting requirements under WDL 211-4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a median mixing zone Total Phosphate (TP) exceedance (100 µg/L) that was recorded on the 30th October 2017 during monitoring of the MOF mixing zone locations, which exceeded the trigger criteria by more than two times. The Phosphate Total (as P) concentration recorded at the upstream reference location (HYDRO-NORTH, based on an incoming tide) did not exceed the trigger criteria. JKC became aware of the exceedance on the 8th November, 2017, following reporting by its Environmental Monitoring Subcontractor. Details of the exceedances, detected during the surface water monitoring sampling event are outlined below: • 30th Oct, 2017 - A median exceedance of 100 µg/L for TP was detected at the MOF mixing zone monitoring locations for authorised discharge location DL2, as defined in Table 3 of WDL 211-4, a value that exceeded the trigger value by more than two times. • Exceedances of the TP trigger value were not detected at the upstream reference site, with a value of 17 µg/L , nor at the downstream site, with a value of 23 µg/L. • The surface water sampling was undertaken on 30th October, 2017 at 11:58AM, during an incoming tidal phase with a 0.75 m amplitude [neap tide]. • Sampling of the C600 basin, which was undertaken on the 26th October 2017, prior to discharge, demonstrated a recorded value of 160 µg P/L, which following dilution through the diffuser [minimum 80 fold], is not sufficiently high enough to result in the concentrations recorded at the mixing zone monitoring locations. • The lack of TP exceedance at the downstream site does not align with a plume source signature coming from the diffuser. JKC has prepared the control chart (e.g. section 6.4.3.3, of the ANZECC monitoring and reporting guidelines), which compares the TP median exceedance with the long term 80th percentile for the wet season reference site data collect from the EIMP. The reference data has been collected from the four EIMP reference sites and the upstream reference sites from the WDL211-4 and the WDL192-3 monitoring programs.

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The TP mixing zone exceedance data exceeds the 80th percentile for the reference sites. The exceedance of the 80th percentile is a trigger for further investigation. Further investigation Construction water sampling was undertaken prior to discharge via the MOF outfall, with the most recent sample collected on the 26th October 2017. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (Document No. L290-AH-PLN-10231). The sampling returned a TP value of 160 µg/L, which after 80 fold dilution through the outfall is not sufficient to result in the concentrations detected at the mixing zone monitoring locations. Therefore, the potential for environmental harm to the receiving environment receptors (water column, soft bottom benthic) associated with the discharge is Low. It is noted that the 80th percentile is calculated using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally, whereby the 80th percentile warns us when we are approaching the maximum values expected at the site. Further review of the chart shows that the reference sites also exhibited higher TP concentrations at times during the 2016/17 wet season. The TP exceedances detected during sampling of the mixing zone are considered to represent seasonal harbour based influences and as such were not associated with the WDL211-4 discharges. The median exceedance observed at the mixing zone monitoring locations is not believed to be attributable to the MOF discharge event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters with no associated risk of environmental harm. For further information, please contact the JKC Approvals Manager Kresho Zic, on 08 8931 8986 Kind regards Shoanne Labowitch Government Approvals Advisor Ichthys Project JKC Australia LNG Pty Ltd Level 6, 66 Smith Street, Darwin City, NT. 0801.

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PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected]

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Chris Gamble

From: Shoanne Labowitch <[email protected]>Sent: Tuesday, 27 March 2018 12:50 PMTo: '[email protected]'Cc: Snyman VanStraaten; Kresho Zic; Anthony BlackSubject: WDL 211-4 Notification of Non-Compliance - median TSS exceedance

Good afternoon, In accordance with the reporting requirements under WDL 211-4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a median mixing zone exceedance of Total Suspended Solids (TSS) (24 mg/L) that was recorded on the 7th March, 2018 during monitoring of the MOF mixing zone locations, which exceeded the trigger criteria of 10 mg/L by more than two times. The TSS concentration recorded at the upstream reference location (HYDRO-SOUTH, based on an outgoing tide) did not exceed the trigger criteria. JKC became aware of the exceedance on the 27th March 2018, following reporting by its Environmental Monitoring Subcontractor. Details of the exceedances, detected during the surface water monitoring sampling event are outlined below: • 7th March, 2018 - A median exceedance of 24 mg/L for TSS was detected at the MOF mixing zone monitoring


• Exceedances of the TSS trigger value were not detected at the upstream reference site, with a value of 9.4 mg/L , however an exceedance was detected at the downstream site, with a value of 32 mg/L.

• The surface water sampling was undertaken on 7th March, 2018 at 10:5AM, during an outgoing tidal phase with a 4.23 m amplitude.

• Sampling of the C600 basin, which was undertaken on the 27th February, 2018, prior to discharge, demonstrated a TSS value of 4.8 mg/L which does not exceed the trigger value. The lack of TSS exceedance at the source does not align with a plume source signature coming from the diffuser.

JKC has prepared the control chart (e.g. section 6.4.3.3, of the ANZECC monitoring and reporting guidelines), which compares the TSS median exceedance with the long term 80th percentile for the wet season reference site data collect from the EIMP. The reference data has been collected from the four EIMP reference sites and the upstream reference sites from the WDL211-4 and the WDL192-3 monitoring programs.

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The TSS mixing zone exceedance data exceeds the 80th percentile for the reference sites. The exceedance of the 80th percentile is a trigger for further investigation. Further investigation Construction water sampling was undertaken prior to discharge via the MOF outfall, with the most recent sample collected on the 27th February, 2018. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (Document No. L290-AH-PLN-10231). The sampling returned a TSS value of 4.8 µg/L, which does not exceed the TV and after 80 fold dilution through the outfall is not sufficient to result in the concentrations detected at the mixing zone monitoring locations. Therefore, the potential for environmental harm to the receiving environment receptors (water column, soft bottom benthic) associated with the discharge is negligible. It is noted that the 80th percentile is calculated using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally, whereby the 80th percentile warns us when we are approaching the maximum seasonal values previously seen at the reference sites. Further review of the chart shows that the reference sites also exhibited TSS concentrations above the 80th percentile value at times during the previous 2016/17 wet season and also during the current 2017/18 wet season. The TSS exceedances detected during sampling of the mixing zone are considered to represent seasonal harbour based influences and were not associated with the WDL211-4 discharges. The median exceedance observed at the mixing zone monitoring locations is not believed to be attributable to the MOF discharge event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters associated with Darwin Harbour seasonal cycles, with no associated risk of environmental harm. For further information, please contact the JKC Environment Manager Kresho Zic, on 08 8931 8986. Kind regards Shoanne Labowitch Government Approvals Advisor

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Ichthys Project JKC Australia LNG Pty Ltd Level 6, 66 Smith Street, Darwin City, NT. 0801. PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected]

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Chris Gamble

From: Shoanne Labowitch <[email protected]>Sent: Tuesday, 21 August 2018 9:35 AMTo: [email protected]: Anthony Black; Kresho ZicSubject: WDL 211-4 Notification of Non-Compliance with Trigger Values for NOx - 19 July

2018

Good afternoon, In accordance with the reporting requirements under WDL 211-4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a mixing zone median exceedance of the trigger value for Oxides of Nitrogen (NOx), which was more than double the 20 µg/L trigger value, and was not also present at the upstream reference site, as per Appendix 3 of WDL 211-4. The median exceedance was detected during surface water monitoring activities undertaken on 19th July, 2018. Monitoring was associated with the discharge of AOC waters from the C600 holding basin. JKC received the sampling results information yesterday, 20th August, 2017, from its Environmental Monitoring Subcontractor following compilation of the dataset and completion of quality assurance reporting. JKC has requested Subcontractor efforts to ensure sampling results are provided in a more expedient manner going forward. Details of the exceedance detected during the surface water monitoring sampling event are outlined below:




3. End of pipe sampling was undertaken on 17th July, 2018, 2 days prior to discharge via the MOF outfall. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (Document No. L290-AH-PLN-10231). The sampling returned an Oxides of Nitrogen value of 710 µg/L, which following dilution of 80 fold, is not sufficient to result in the observed median exceedance at the mixing zone monitoring locations.







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Further investigation Construction water sampling was undertaken prior to discharge via the MOF outfall, with the most recent sample collected on the 17th July, 2018. The results were then used for the end of pipe comparison as per Table 1.1 of the Ichthys Onshore LNG Facilities Hydrotest Discharge: Environmental Monitoring Plan – Supporting Documentation (Document No. L290-AH-PLN-10231). The sampling returned an Oxides of Nitrogen value of 710 µg/L, which following dilution of 80 fold, is not sufficient to result in the observed median exceedance at the mixing zone monitoring locations. Further, this sampling event forms one of a series of monitoring events for the discharge which ran from 17th July through to 31st July 2018. There were no other median exceedances of NOx in the discharge prior to and after the reportable event, which demonstrates that the exceedance is not related to the discharge event. Therefore, the potential for the NOx exceedance to be attributed to the discharge, and potential for environmental harm to the receiving environment receptors (water column, soft bottom benthic) associated with the discharge is negligible.

It is noted that the 80th percentile is calculated using the reference data, and as such the top 20th percentile of the reference data will also exceed the value, naturally, whereby the 80th percentile warns us when we are approaching the maximum seasonal values previously seen at the reference sites. Further review of the chart shows that the reference sites also exhibited NOx concentrations above the 80th percentile value at times during the previous 2016/17 wet season and also during the current 2017/18 wet season. The NOx exceedances detected during sampling of the mixing zone are considered to represent seasonal harbour based influences and were not associated with the WDL211-4 discharges. The median exceedance observed at the mixing zone monitoring locations is not believed to be attributable to the MOF discharge event. The contributing factors associated with the non-compliance are attributed to heterogeneity in the sampling of waters associated with Darwin Harbour seasonal cycles, with no associated risk of environmental harm.

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For further information, please contact the JKC Environment Manager Kresho Zic, on 08 8931 8986. Kind regards Shoanne Labowitch Government Approvals Manager Ichthys Project JKC Australia LNG Pty Ltd T300, 130 The Esplanade, Darwin, NT, 0800 PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 [email protected]

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From: Shoanne Labowitch <[email protected]>Sent: Friday, 7 September 2018 9:58 AMTo: [email protected]: Kresho Zic; Anthony BlackSubject: WDL 211-4 Notification of Non-Compliance with Trigger Values - September 2017

Good afternoon, In accordance with the reporting requirements under WDL 211‐4, specifically Licence Condition 23.2 and Condition 40, JKC Australia LNG Pty Ltd (JKC) hereby notifies NT EPA of a mixing zone median exceedance of the trigger values for Total Suspended Solids (TSS), and Copper (filtered). JKC received the sampling results information today, 7th September, 2018, from its Environmental Monitoring Subcontractor following completion of the WDL‐211 Annual Report and Annual Return, where it was discovered that a WDL‐211 analysis Report, submitted on 20th September, 2017, had erroneously stated two median impact site exceedances as not reportable when they were in fact reportable to NT EPA. These were:

1. MOF Discharge Monitoring event on the 1st September, 2017 reported a median TSS of 20 mg/L at the edge of the mixing zone, which is equal to double the trigger criteria (10mg/L). The TSS concentration at the upstream reference site (HYDRO‐SOUTH, based on an outgoing tide at the time of sampling) was recorded at concentrations equal to the trigger criteria (10 mg/L); and

2. MOF Discharge monitoring event on the 13th September, 2017 reported median copper (filtered) concentrations of 3 µg/L at the edge of the mixing zone, which exceeded the trigger criteria (1.3 µg/L ) by more than double. The copper (filtered) concentration at the upstream reference site (HYDRO‐SOUTH, based on an outgoing tide at the time of sampling) did not exceed the trigger criteria (recorded at <1 µg/L).

Relevant details pertaining to each exceedance are as follows: Total Suspended Solids (1st September 2017)

Monitoring undertaken on the 1st September, 2017 during the discharge of spent construction waters reported a median TSS concentration of 20 mg/L at the monitoring sites, which exceeded the trigger value by equal to double. The exceedance was not observed at the upstream reference site HYDRO‐SOUTH (10 mg/L), as determined by an outgoing tide phase at the time of sampling. Exceedances were recorded at all mixing zone monitoring locations, with concentrations ranging between 13 to 26 mg/L with two reference/control sites exceeding the trigger value. The TSS concentration measured in the spent waters prior to discharge was 2.3 mg/L and achieved the end of pipe trigger value criteria for discharge via authorised discharge location DL2. The TSS concentrations recorded at the 19 EIMP monitoring sites in September 2017 ranged from 7 to 36 mg/L, with exceedances recorded at 17 of the 19 sites including at 3 of the four reference sites. It was assessed:

‐ that the TSS concentration within the spent waters, following dilution at the diffuser, was not sufficiently elevated to be the source of the elevated TSS concentrations that was recorded in the marine receiving environment.

‐ TSS was ubiquitous in Darwin Harbour during October and September 2017 as evidenced by the EIMP monitoring results.

‐ TSS concentrations at the edge of the mixing zone was not indicative of a sediment plume resulting from discharge activities as TSS concentration at the downstream reference site (HYDRO‐NORTH) was below the trigger value (at 8.3 mg/L).

Chris Gamble

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‐ The median TSS exceedance of 20 mg/L did not exceed the 80th percentile value for reference sites, which demonstrates the reportable exceedance was within the natural seasonal variation of the reference sites and would not have triggered further investigation.

TSS 80th Percentile vs Reportable Exceedance Filtered Copper (13th September 2017)

Monitoring undertaken on the 13th September, 2017 during the discharge of spent construction waters reported a median dissolved copper concentration at the monitoring sites of 3.0 µg/L, which exceeded the trigger value by more than double. The exceedance was not observed at the upstream reference site HYDRO‐SOUTH (<1 µg/L), as determined by an outgoing tide phase at the time of sampling. Exceedances were recorded at all mixing zone monitoring locations, with concentrations ranging from 2.0 to 3.0 µg/L. The filtered copper concentration measured in the spent waters prior to discharge was 1.0 µg/L and achieved the end of pipe trigger value criteria for discharge via authorised discharge location DL2. The dissolved copper concentrations recorded at the 19 EIMP monitoring sites for September 2017 were all below detection at <1 µg/L. It was assessed:

‐ that the dissolved copper concentration within the spent waters, following dilution at the diffuser, was not sufficiently elevated to be the source of the elevated concentrations that were recorded in the marine receiving environment.

‐ The copper concentrations at the edge of the mixing zone was not indicative of a copper plume resulting from discharge activities as the concentration at the downstream reference site (HYDRO‐NORTH) was below detection (at <1 µg/L). Further, there were no copper detections at any EIMP sites in September or the preceding and subsequent months.

‐ The median copper exceedance of 3 µg/L did exceed the 80th percentile value for reference sites however, there have been numerous exceedances reported at upstream reference sites during the period August 2017 to May 2018.

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Filtered Copper 80th Percentile Versus Reportable Exceedance

The Environmental Monitoring Subcontractor has undertaken an audit of all monitoring results taken over the last 12 months to ensure that there have been no other missed instances of reporting in accordance with the licence conditions. They have also advised that they have instituted additional review steps in the notification process to ensure a similar instance of missed reporting does not occur again, If you have any queries or concerns, please feel free to contact me on the number below, Kind regards Shoanne Labowitch Government Approvals Manager Ichthys Project JKC Australia LNG Pty Ltd T300, 130 The Esplanade, Darwin, NT, 0800 PO Box 2079, Darwin, NT. 0801 Office: 08 89 318 735 Mobile: +61 417 027 013 labowitch.shoanne@jkc‐lng.com

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Documents

INDRA...INDRA 28-SEP-2018 UNCONTROLLED WHEN PRINTED DOC-EIMP- Code A.\rAccepted. \rA. Black 28/09/18 GREENCAP PTY LTD 11 Winnellie Central, 14 Winnellie Road, Winnellie, NT 0820, P