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  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 1 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    M-I AUSTRALIA PTY LTD OPERATIONAL

    BROOME ENVIRONMENTAL MANAGEMENT PLAN

    Version number: 1.0

    Original issue date: March 2014

    Scheduled review date: September 2014

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 2 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    TABLE OF CONTENTS

    1. INTRODUCTION

    1.1 Scope

    1.2 Objectives

    1.3 Outcomes

    1.4 EMP Structure

    1.5 M-I Australia Environmental Management System

    1.6 Site Description

    1.7 QHSE Policy

    1.8 Organization

    1.9 Roles & Responsibilities

    2. DESCRIPTION OF OPERATIONS

    2.1 Major Operations

    2.2 Minor Operations

    2.3 Waste Oil Collection

    2.4 Equipment Maintenance

    2.5 Traffic Management

    2.6 Storm Water Management

    2.7 Waste Management

    2.8 Spill Prevention and Control Plans

    3. REGULATORY OBLIGATIONS

    4. DESCRIPTION OF EXISTING ENVIRONMENT

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 3 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    4.1 Regional Setting

    4.2 Physical Environment

    4.3 Vegetation

    5. ENVIRONMENTAL MANAGEMENT CONTROLS

    5.1 Emergency Response

    5.2 Spill Response

    5.3 Cyclone Emergency Response

    5.4 Noise Management

    5.5 Insect / Vermin Vector Management

    5.6 Air Quality

    5.7 Bushfire Management

    5.8 Contractors and Carriers

    5.9 Implementation of Emergency Response Plan

    5.10 Key Activities

    6. ENVIRONMENTAL RISK REGISTER

    6.1 Definitions

    6.2 Environmental Events

    6.3 Environmental Risks of Significance to M-I Australia Operations

    7. REFERENCES

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 4 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    1. INTRODUCTION

    M-I Australia has been operating within the North West of Western Australia for more than 30 years,

    and within the Broome Light Industrial Area (LIA) and Broome Port since 2008. The primary role of M-I

    Australia facilities is to provide drilling fluids of both Water Based and Synthetic based make up, along

    with associated palletized and bulk materials for conditioning the fluids offshore.

    During the past 30 years M-I Australia has supplied drilling fluids for the offshore Oil and Gas industry in

    Australia without any major incident or impact to the local environment, and continues to be the

    industry leader in product quality, safety, environmental and operational standards.

    Drilling fluids are blended and reconditioned on site and stored in vertical tanks until required by drill

    rigs. All blending and conditioning of fluids is conducted within an enclosed mixing shed facility and

    under controlled conditions with trained plant operators. All material is delivered to/from the rig site via

    Platform Supply Vessels who currently berth at the wharf located within Broome Port Authority

    grounds, with all materials being delivered to the wharf via road tankers.

    Company details are as follows;

    Legal Entity: M-I Australia Pty Ltd.

    ABN: 67 009 214 162

    Site Address: Lot E3 Port Drive

    Broome, Western Australia, 6725

    Site Manager: Jeff Hall

    Phone: +61 8 9193 7866

    Title details: Lot 621 on Deposited Plan 70861 Qualified Certificate of Crown Land

    Title Volume LR3162 Folio 732; and

    Lot 698 on Deposited Plan 209491 Qualified Certificate of Crown Land

    Title Volume LR3002 Folio 356

    1.1 Scope

    The Operational Environment Management Plan (OEMP) is applicable to the following activities:

    a) All activities conducted by M-I Australia within Lot E3, Port Rd, Broome.

    b) Those operations conducted by contractors who operate within the Site under M-I Australias

    direct control.

    c) M-I Australia employees and contractors will operate in accordance with the BrPA Environment

    Management Plan when outside of Lot E3 but within the Port Management Area.

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 5 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    1.2 Objectives

    The objectives of this OEMP are:

    a) To identify and consider the environmental aspects at the Site;

    b) To assess the risks associated with the identified environmental aspects and prioritize them for

    action;

    c) To identify environmental management options and strategies to assist M-I Australia in meeting

    its environmental management obligations, taking into account existing procedures and

    mitigation measures; and

    d) To describe specific procedures / processes to be implemented by M-I Australia.

    1.3 Outcomes

    The desired outcomes of the OEMP are:

    a) A consistent and structured approach to environmental management;

    b) To ensure M-I Australia staff and contractor awareness of their shared responsibility to protect

    the environment;

    c) Reduction in operating costs by reducing the need for remedial actions; and

    d) Effective environmental management in accordance with legislative requirements.

    1.4 OEMP Structure

    The OEMP is an umbrella document that describes a framework for environmentally sustainable

    management at the Site. An activities-based approach has been adopted given that a number of

    different activities are conducted on site.

    This document comprises the following sections:

    a) Section 1, provides a general overview of site, looking at objectives, structure and key roles and

    responsibilities related to the OEMP.

    b) Section 2 provides a detailed description of key activities and environmental aspects at the Site.

    c) Section 3 summarizes M-I Australias obligations with respect to the environment under various

    State and Commonwealth legislation.

    d) Section 4 details the existing environment at the Site.

    e) Section 5 summarizes the Environmental Management Controls in place.

    f) Section 6 summarizes how events are recorded and some of key environmental risks to

    applicable to M-I Australia Operations.

    g) Section 7 summarizes key references

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 6 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    1.5 M-I Australia Environmental Management System

    The M-I Australia Environmental Management System incorporates policies, planning, procedures,

    practices, responsibilities, training, monitoring, review and audits that together define a framework for

    managing the impact of M-I Australias activities, products and services on the environment.

    This OEMP forms part of M-I Australias Emergency Management System. It will be reviewed periodically

    and may be revised to incorporate changes in legislation, updated guidelines or altered management

    practices. It may also be reviewed in response to an environmental incident or the identification of new

    or changed environmental risks.

    1.6 Site Description

    The Lot E3 facility is located within the Port Management Area at the Southwest tip of the Dampier

    Peninsula, in the general area of Entrance Point, Broome, Western Australia. The location of Lot E3

    within the Port Management Area is shown in Figure 1.

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 7 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    Figure 1: Site Location Image courtesy of Golder and Associates

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 8 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    Figure 2: Lot E3 site layout

    1.7 QHSE Policy

    M-I Australia recognizes that the protection of the environment is a key business performance objective,

    and this has been reflected in the development of our Emergency Management System. The key

    requirement of our policy is to Minimize our impact on the environment through pollution prevention,

    reduction of natural resource consumption and emissions, and the reduction and recycling of waste.

    1.8 Organizational Structure

    The table below reflects the organizational arrangements for operations on M-I Australia sites.

    1.9 Roles and Responsibilities

    All personnel employed on M-I Australia Sites have general obligations under legislation as follows:

    Country Manager

    Operations Manager

    Site Manager

    Warehouse Personnel

    Quality Operations

    Support Manager

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 9 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    They must take reasonable action to ensure no person or property is exposed to more than an

    acceptable level of risk;

    They must comply with safety procedures and obligations defined within this OEMP;

    They must avoid wilful or reckless acts that might adversely affect the safety of anyone at the

    facility; and

    They must minimize their impact on the environment through pollution prevention, reduction of

    natural resource consumption and emissions, and the reduction and recycling of waste.

    1.9.1 Site Manager Key Roles and Responsibilities

    a) To ensure the overall smooth-running of all warehouse and mud plant operations, maintenance of

    plant and equipment, movement of material and all related documentation.

    b) Ensure communication relating to the warehouses is maintained with all relevant departments and

    that all contractually related paperwork and data is distributed as required.

    c) Implementation of QHSE Program.

    d) Ensure that all materials are stored safely, and packaged in accordance with the company and

    clients standard procedures.

    e) Assure the safe and proper loading and use of assigned vehicles.

    f) Ensure safety, discipline and motivation of all personnel reporting to self.

    g) Be responsible for all relevant operational information and documentation presented to the

    Operations Manager or Country Manager as appropriate.

    h) Communicate with all relevant parties required to oversee everyday business.

    i) Ensure through communication and inspection, when necessary, that all Broome Warehouse and

    Mud Plant equipment is operational, maintained, calibrated and certified.

    j) Co-ordination of material movements to/from rigs and bulk mud mixing to specification.

    k) Liaison with the Operations Department for mud formulations.

    l) Assist with maintenance of up-to-date inventory records and mud plant volumes.

    m) Implementation of QHSE in warehouse/mud plant/bulk plant and implementation waste

    management procedures according to the Duty of Care requirements.

    1.9.2 Quality Operations Support Manager Roles and Responsibilities

    a) Supports the development, maintenance, implementation, & improvement of the Quality

    Management Processes and Procedures.

    b) Maintains Facility Site Manager, Line Manager or Operation Managers Quality Awareness such that

    Quality is an integral part of Geo Market/Area Management responsibilities and objectives.

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 10 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    c) Ensures Geo Market Management maintains ownership of all Service Quality related reviews.

    d) Supports Geo Market Management to define, implement, and monitor Service Specific Key

    Performance Indicators.

    e) Assists planning of the required infrastructure & resources and assists Geo Market to deliver

    required Service Quality results.

    f) Ensures the implementation of specific competency (as well as associated training) requirements for

    Employees and Contractors as required.

    g) Provides planning, coordination, communication, and active & visible support and assurance for

    quality compliance including status, results, follow-up, and actions as required.

    h) Ensures that systems providing asset integrity are suitable and sufficient.

    i) Ensures the work place facilities are appropriate for activity level and type.

    1.9.3 Operations Manager Roles and Responsibilities

    a) Manages the Fluids (Drilling and Completion Fluids) Operations for Australia.

    b) Responsible for the Fluids Facilities and Fluids Personnel involved in the receipt and supply of

    product to the field, with respect to meeting operational, HSE, quality, training and budgetary

    needs.

    c) Responsibility include employee management anddevelopment,inventory management,

    maintenance, operations, service, HSE, quality, training, planning and budget management.

    1.9.4 Warehouse Personnel Roles and Responsibilities

    a) Co-ordination of material movements within the warehouse.

    b) Bulk mud and brine mixing to specification as per company procedures and related documentation

    where applicable.

    c) Maintenance and inspection of all plant and equipment.

    d) Assist with the maintenance of up-to-date inventory records and mud plant volumes.

    e) Safe Forklift operations according to company and legislative procedures.

    f) Driving duties using company vehicle (where applicable) (deliveries and collections).

    g) Safe loading and unloading of containers, boats, tanks etc. in accordance with company procedures.

    h) Following company inspection and testing procedures for products/materials arriving into the

    warehouse and deliveries to customers.

    i) Take samples of products as instructed by the Warehouse Manager according to company

    procedure. Samples are required to be logged and stored correctly.

    j) General duties within the yard, mud plant and bulk plant.

    k) Adherence to waste management procedures according to Site-specific plan.

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 11 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    l) Ensure that company vehicles are driven in a safe coherent way in line with company policy.

    m) Maintain vehicles in a safe, clean condition and report any faults to management.

    2. DESCRIPTION OF OPERATIONS

    Lot E3 is located on the north eastern side of Port Drive within the Broome Port Authority area. The site

    is bordered to the east by Roebuck Bay with a nature reserve separating the site from the beach area.

    To the North of the site there is a natural coastal bush block and on the bay there is a hovercraft base

    supporting the tourism industry. To the West, is Port Drive, with a large logistical facility operated by Toll

    Mermaid and a Bulk Fuel Storage Depot operated by both Shell and BP. The South of the site is a

    limestone road train break up and turn around facility mainly used for road trains servicing the adjacent

    fuel depot. The entire site is to be secured through 6 foot cyclone fencing with two feet of barbed wire

    runs atop, and secured gates such that the facility can be completely locked down during periods of

    inactivity.

    The entire site is to be sealed with either concrete bunds or two coat bitumen seal to ensure any and all

    materials on site are completely contained. One third of the site consists of concrete bunds to provide

    secondary containment of all fluids materials stored on site, and catch approximately 1/3 of storm water

    that falls on site. This in turn reduces the amount of storm water discharge from the site by

    approximately 1/3 as all of the storm water collected in bund areas will be recycled and used in the

    making of brines. All warehousing on site has been designed to be weather resistant such that storm

    water will not penetrate them.

    To assist in water management on site a water monitoring well has been installed on the eastern side of

    the lot, closest to the bay. Regular ground water monitoring will be conducted by M-I Australia and

    Broome Port Authority as per Broome Port Authority TEMR requirements.

    The site has been designed such that the warehouse is closest to the Roebuck Bay area. The rear of the

    warehouse only has emergency personnel access doors such that all material stored within the

    warehouse cannot make its way towards the bay. The liquid tank storage areas are located on the Port

    Drive side of the site such that emergency access to tanks is available from all sides, with fire and

    emergency vehicles being able to park vehicles on any side of the tank farm should the need ever arise.

    All fluid mixing on site is to be conducted within the mixing shed and all bulk powder cutting operations

    are to be conducted within the large warehouse. These buildings are self bunded and self-contained

    such that any release of material is contained within the concrete foundations and able to be collected

    and disposed of through third party approved waste disposal contractor.

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 12 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    A septic system will be installed on site for the handling / storage of sewage in accordance with Health

    Act 1911, Heath(Treatment of Sewage and Disposal of Effluent and Liquid Waste) Regulation 1974.

    2.1 Major Operations

    Mixing of Synthetic Based drilling fluids;

    o Conducted within Bunded Mixing Shed.

    o Processes utilize specifically designed Venturi system to ensure safe blending of all

    materials, both powdered and liquid.

    Mixing of Water Based drilling fluids;

    o Conducted within bunded mixing shed.

    o Processes utilize specifically designed Venturi system to ensure safe blending of all

    materials, both powdered and liquid.

    Testing of drilling fluid properties;

    o Conducted within Specifically design Mud laboratory located within mixing shed.

    o Fluid testing within lab to be conducted by qualified Drilling Fluid Engineers only.

    Loading out drilling fluids to Platform Supply Vessels;

    o Conducted over specifically engineered bunded concrete load-out bays.

    Back loading drilling fluids from Platform Supply Vessels;

    o Conducted over specifically engineered bunded concrete load-out bays.

    Cutting Bulk Powdered Product;

    o Conducted within the large warehouse, fully enclosed area.

    o Operations utilize specifically designed dust collecting system.

    o Loading out Bulk Powdered Product conducted over concrete load-out pad.

    o Operations utilize specifically designed dust collecting system.

    2.2 Minor Operations

    Centrifuging and reconditioning of used fluids;

    o Conducted within Bunded Mixing Shed.

    o All drill solid fines and waste to be disposed of through approved third party waste

    disposal contractor.

    o All used disposal containers are to be sealed within mixing shed upon completion of

    processing.

    Storage of Synthetic Based Fluids;

    o Fluids contained within specifically designed 1,100bbl storage tanks.

    o All tanks contained within engineered concrete bunds for secondary containment.

    o Tanks are fitted with radar fluid level monitoring system, with overflow prevention.

    o Tanks also have overflow pipes down to 900mm off ground level to ensure fluids 100%

    contained within concrete bund foundations.

    Storage of Water Based Fluids;

    o Fluids contained within specifically designed 1,100bbl storage tanks.

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 13 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    o All tanks contained within engineered concrete bunds for secondary containment.

    o Tanks are fitted with radar fluid level monitoring system, with overflow prevention.

    o Tanks also have overflow pipes down to 900mm off ground level to ensure fluids 100%

    contained within concrete bund foundations.

    Storage of Bulk Powdered Products;

    o All contained inside the large warehouse on site.

    o All Bulk powdered material stored in plastic lined woven polypropylene bulk bags.

    o All Bulk Bags stored out of sunlight to ensure UV breakdown of bags cannot occur.

    Storage of Palletized Materials;

    o All palletized liquid materials to be stored in bunded concrete storage area.

    o All powdered sack materials to be stored in dedicated bunded storage area or

    warehouses.

    o All materials to be shrink-wrapped in UV rated Black Plastic for additional protection.

    Storage of Dangerous Goods;

    o All Bulk liquid DG material to be AS-1940 compliant storage tank farm.

    o All Bulk Liquid Storage tanks to be contained in concrete bunded storage area.

    o All palletized DG materials to be stored correctly in specifically engineered and design

    Dangerous Goods Storage Shed located in North West corner of yard.

    o All dangerous goods on site to be stored and handled as per 2007 Dangerous Goods

    regulations, and as stated by Dangerous Goods Consultant.

    Repalletization of products;

    o To be conducted within Large enclosed warehouse.

    o To be done with use of pallet inverter to minimize sack handling and potential spills.

    o All palletized material to be covered in additional UV rated black plastic protective

    covering.

    2.3 Waste Oil Collection

    Any waste oil or other associated hazardous waste is periodically collected and disposed of by a licensed

    waste carrier. All waste oil collected on site is stored in 1000L Intermediate Bulk Containers which are in

    turn stored within concrete bunded areas for secondary containment. Waste oils are then removed

    from site by third party waste disposal contractor and transported to their facility for disposal. In

    addition a licensed waste services provider will be periodically contracted to pump out the sumps of the

    designated bunded areas and other waste collection when sumps are nearing capacity.

    Each concrete bund is engineered to Australian Standards and designed to contain fluid should any

    container or tank experience a leak or rupture. Each bund has a self-contained, mesh grated, one cubic

    meter sump that has been designed such that vacuum trucks are able to lower hoses into them to

    remove fluid levels below the floor level surface of the concrete foundation. This ensures that maximum

    amount of fluids can be removed from bunds and minimizes the potential for remaining residue.

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 14 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    2.4 Equipment Inspection & Maintenance

    General cleaning and maintenance of onsite equipment (pumps, compressors, forklifts) is conducted by

    approved third party contractors. Any waste generated from such activities is removed by the third

    party conducting the maintenance. All maintenance of equipment is to be conducted within the bunded

    warehouse area to ensure that materials associated with maintenance cannot enter the general

    surroundings. Maintenance areas have been designed such that all equipment undergoing maintenance

    can be stored without impacting site operations.

    All bulk silos are periodically inspected and certified as per AS-3788 (Pressure Vessel Testing) by a

    government approved third party certification agent, in addition periodic visual checks are conducted

    internally of all tanks, piping and associated fittings. All bulk silos are registered through WorkSafe WA.

    Pressure Relief valves in place on bulk silos are inspected by NATA certified testing agents on an annual

    basis. In addition all associated pressure gauges are tested and replaced as required annually by a NATA

    certified agent.

    All Liquid bulk tanks are manufactured to API-650 and are periodically inspected.

    2.5 Traffic Management

    Lot E3 utilizes a one way traffic flow system in order to help mitigate the risk of a motor vehicle related

    incident occurring within the base. Traffic will enter off Port Drive and exit through the side gate onto

    what is currently known as the Hovercraft base road. The posted maximum speed for the base will be

    15km/h. All loading and unloading operations will occur within designated loading zones only.

    Please see below diagram showing the traffic flow within the facility.

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 15 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    Figure 2.5: Traffic Management diagram

    2.6 Storm Water Management

    Storm water control measures are in place including:

    a) Storm water collected within a bund will be processed through an oil and water separator and water

    pumped is then pumped to the brine mixing facility for re-use within the plant.

    b) Storm water collected in the two retention ponds is to be tested prior to discharge. If testing is

    within required limits the water is then pumped via spray bar over rock pitching and released to the

    environment. If Storm water does not meet specification it is processed through the oil/water

    separator and tested again. If quality does not meet discharge standards an approved third party

    waste disposal contractor will pump retention ponds dry and dispose of the fluid as per regulation.

    c) Prior to first rainfall event at the commencement of the wet season, water monitoring results will be

    submitted to the Shire of Broome within an agreed period of 7 days from receipt.

    Water testing Criteria

    pH Between 6.5 and 7.5

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 16 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    Oil Less than 10ppm

    Solids Less than 0.2% TSS

    Turbidity Less than 40 NTU

    Chlorides Less than 40,000mg/L

    Hardness Less than 300mg/L

    Where water fails to meet testing limits for release it is then collected by an approved waste disposal

    contractor.

    During exceptional rainfall events, storm water can sheet flow overland off the site, transporting

    sediment and potentially oil contaminated water toward Roebuck Bay. For this reason considerable care

    is taken to keep the site clean and an independent environmental audit on an occasional basis is

    conducted.

    2.7 Waste Management

    Strategies to minimize the potential for disposal liability are employed such as:

    Reducing the amount of waste generated.

    Limiting the number of disposal companies used.

    Compaction of waste generated to reduce volume.

    Companies contracted for the disposal of waste are audited in accordance with SLB-QHSE-S008

    Environmental Standard. Only approved waste service providers are used for disposal of hazardous and

    non hazardous waste.

    M-I Australia handles different types of wastes including:

    Products that are classified as hazardous to the environment i.e. used oil, waste paints, used

    solvents etc.

    Products that are non hazardous i.e. used pallets, paper etc.

    Common waste at M-I Australia facilities includes:

    Damaged product containers (sacks, bags, drums, plastic containers, barrels).

    Empty product containers (sacks, bags, drums, plastic containers, barrels).

    Unusable product.

    Drill solids acquired from centrifuge process.

    Waste oil.

    Used oil filters.

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 17 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    Unserviceable plant, equipment and components.

    Soiled rag (oil, grease, chemical).

    Empty paint and aerosol cans.

    Used solvents and cleaning fluids.

    Administrative waste (paper, cardboard, printer and copier cartridges, alkaline batteries).

    Unserviceable office equipment (computers, printers, photo copiers, telephones).

    Unserviceable office furnishings (chairs, desks, tables, shelving, cupboards).

    Obsolete laboratory chemicals.

    Obsolete mud samples.

    Before handling any waste, M-I Australia ensures the related physical, chemical, environmental and

    health hazards are understood. This includes ensuring that:

    Containers are correctly labeled.

    Containers are in good order and condition.

    Material Safety Data Sheet (MSDS) is available for the product.

    Appropriate Personal Protective Equipment (PPE) is used to handle waste and containers based

    on the type of waste involved. Equipment may include gloves, eye protection etc.

    Below table (2.7.1) is to be completed to ensure roles and responsibilities are clearly assigned

    for the management of waste streams.

    Below table (2.7.2) is a copy of the template use for waste classification and disposal routes.

    Table 2.7.1

  • Prepared by: Richard Taylor

    BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP

    Verified by: Courtney Girdwood

    Operational Environmental PlanOperational Environmental PlanOperational Environmental PlanOperational Environmental Plan Rev:06 Page 18 of 43

    Approved by: James Cobb Issued: 10th Mar 2014

    Table 2.7.2

    Storage

    M-I Australia requires weekly inspections of all chemical storage areas. Inspections must be documented

    using the Weekly Storage Checklist Form and should address:

    1. Are all containers free of leaks, corrosion and deterioration? If leaks, corrosion or deterioration

    is evident has the product been classified as Grade B or Grade C waste product?

    2. Is an accurate manifest on hand specifying exact quantities of Grade B and Grade C waste

    products?

    3. Is each container clearly marked with a label stating its contents?

    4. Do all products classified as dangerous goods have appropriate hazard labels?

    5. Are sacks, bags, drums, plastic containers, barrels or pallets stored with sufficient aisle space

    and at a level which allows access to inspect and/or respond to leaks?

    6. Are used oil containers clearly labeled Used Oil?

    7. Are absorbent materials and other spill cleanup equipment available in sufficient quantities?

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    8. Is PPE available in accordance with MSDS recommendations for all products?

    9. Is first aid equipment available in the area and in sufficient quantities?

    10. Is area suitably signposted as a Waste Product Storage Area?

    2.8 Spill Prevention and Control Plans

    In the event of a Spill during the unloading or loading process, the control measures in place are as

    follows:

    Continuous monitoring of hoses and connections is conducted by the M-I Australia employee in

    accordance with Standard Operation procedures (Dry break couplings are utilized for transfers

    to minimize any spills that may occur.

    All hose connections coupled outside bunded areas are to be controlled through use of

    appropriately sized drip trays.

    All Synthetic base fluid tanks and mud tanks are contained within a bunded area designed to

    contain 110% of the largest vessel enclosed in accordance with AS-1940, plus 125mm to account for a 125mm in 24 hour rainfall event.

    All drum products are contained with a bunded area.

    Spill recovery kits are located at the facility.

    Detailed Spill Response Procedures are available in the event of a spill at the facility. Response

    procedures are in place for Base Fluids, Brines, diesel, Bulk powders etc. An example is included

    as Figure 2.2.

    Note: All Secondary containment structures are periodically inspected and tested as per Figure 2.8.1

    (Test and Inspection Record Form)

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    Figure 2.8.1: Test Inspection record form

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    Figure 2.8.2: Extract Broome Spill Prevention and Control Plans

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    3. REGULATORY OBLIGATIONS

    A key policy objective of M-I Australia Pty Ltd is compliance with environmental legislation'. M-I

    Australia, its staff and its Contractors are required under the Environmental Protection Act 1986 (EP Act)

    to prevent environmental harm, and also have a duty of care under common law to protect the

    environment from foreseeable risks.

    Under the Schedule 1 of the Environmental Protection Regulations 1987, the M-I Australia facility will

    comprise Category 73 & 75 Prescribed Premises (refer section 2 for additional detail). A License to

    operate under Part V of the EP Act is therefore required at the Site.

    Under the Port Authorities Act 1999, BrPA oversees all activities within the Port Management Area. The

    Site comprises part of the Port Management Area, and is zoned Port Zone under Broome Shire Town

    Planning Scheme No. 4.

    M-I Australia is establishing a register of legal and other requirements containing all environmental

    permits, licenses, works approvals and Ministerial conditions relevant to its operations. The following

    legislation has been identified as relevant.

    Environmental protection;

    EP Act.

    Environmental Protection Regulations 1987.

    Environment Protection and Biodiversity Conservation Act 1999 (Commonwealth).

    Noise, dust, emissions;

    Environmental Protection (Noise) Regulations 1997.

    Environmental Protection (Unauthorized Discharges) Regulations 2004.

    Environmental Protection (Ozone Protection) Policy Approval Order 2000.

    Environmental Protection (Diesel and Petrol) Regulations 1999.

    Waste and pollution;

    Contaminated Sites Act 2003.

    Environmental Protection (Controlled Waste) Regulations 2004.

    Environmental Protection (Landfill) Levy Act 1998.

    Guidelines for Acceptance of Solid Waste to Landfill 2002.

    Pollution of Waters by Oil and Noxious Substances Act 1987.

    Environmental Protection and Biodiversity Conservation Act 1999.

    Water supply and sewerage;

    Country Areas Water Supply Act 1947.

    Dangerous goods;

    Explosives and Dangerous Goods Act 1961.

    Dangerous Goods (Transport) Act 1998.

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    Dangerous Goods (Transport (General) Regulations 1999.

    Dangerous Goods (Transport (Explosives by Road and Rail) Regulations 1999.

    Dangerous Goods (Transport) (Road and Rail) Regulations 1999.

    Aboriginal heritage;

    Aboriginal Heritage Act 1972.

    Aboriginal Communities Act 1979.

    Conservation and Wildlife;

    Conservation and Land Management Act 1984.

    Agricultural and Related Resources Protection Act 1976.

    Soil and Land Conservation Act 1945.

    Soil and Land Conservation Regulations 1992.

    Wildlife Conservation Act 1950.

    While care was taken to identify all relevant legislation, these tables should not be assumed to contain

    every possible statute.

    4. DESCRIPTION OF THE EXISTING ENVIRONMENT

    This section provides an overview of the existing receiving environment. It is described in terms of the

    regional setting, physical environment, ecological features and socioeconomic features.

    4.1 Regional Setting

    The Site is situated on the Dampier Peninsula and is 5km south-west of Broome town site and located

    within the boundaries of the Port Management Area. The area surrounding Lot E3 is currently natural

    coastal bush land. Lot E3 currently slopes westwards towards Port Drive and current drainage is

    determined by the existing environmental lay of land.

    The site is bounded to the North-West by an access way to Broome Hovercraft base and beyond that is

    an undeveloped block of remnant native vegetation. To the North-East the property is bounded by

    native vegetation corridor which stretches to Roebuck Bay. South-East the property has a soft stand

    road train lay-down and turn around bay, while the South West is bounded by Port Drive.

    4.2 Physical Environment

    The site is bounded to the east by Roebuck Bay with a native vegetation and pindan cliff conservation

    area separating the site from the bay. Site drainage has been designed to minimize the current impact of

    erosion to the pindan cliffs, and is to be monitored and modified as per required to ensure the

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    protection of the natural vegetation and erosion of this area. Site drainage plan incorporates the

    catchment of one third of storm water on site to assist in reducing the current downstream erosion

    potential.

    Heritage studies have determined that there is no significant site within the boundaries of the lease

    area, and has been confirmed by the Department of Aboriginal Affairs. There are some significant sites

    located close by in the bay area and due to the sensitive nature of these sites all practices are to be

    employed to protect these sites from damage or erosion due to any and all operations on site.

    4.2.1 Climate

    The site is arid, however Rainfall is generally low (avg. ann. ~517mm), and demonstrates a summer peak

    (cyclone season), with a lesser winter peak occurring in response to high pressure system traversing

    southern Australia (Figures 4.2.1 and 4.2.2). The late winter-spring period is generally dry. Temperatures

    range from a minimum average of ~14C in winter, to an average peak approaching 35C in summer.

    Wind at the site is largely Westerly (winter) and Easterly (winter) in the morning, swinging south-east

    and north east respectively in the afternoon (Figure 4.2.3). Wind strengths are generally less than

    15knots, but can exceed 20knots.

    Figure 4.2.1: Average Rainfall

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    Figure 4.2.2: Average Minimum and Maximum Temperature

    Figure 4.2.3: Wind strength and Direction for 9am and 3pm observations (source BoM)

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    4.3. Vegetation

    Plant communities in the Port Management Area and surrounds have been surveyed and described by

    LeProvost Environmental Consultants (1990) and Woodman Environmental Consulting (2008, 2009). The

    native vegetation present has been determined to be of non-threatened varieties, and processes and

    practices implemented on site are designed to eliminate any disturbance to vegetation within

    surrounding areas.

    Additional site inspections have been undertaken by Coffey Environments (2013a, b). Based on results of

    an independent environmental site investigation conducted in 2013 the TEC monsoon Thickets, the PEC

    Mangarr community and the threatened Keraudrenia exastia were not reported to occur within the site

    boundaries of Lot E3.

    Monthly site inspections include visual inspection of surrounding areas.

    5. ENVIRONMENTAL MANAGEMENT CONTROLS

    Various guidelines procedures have been developed by M-I Australia to manage the impacts of its

    operations on the environment. These procedures are detailed in a number of documents, primarily:

    a) Environmental Standard (SLB-QHSE-S008).

    b) Documentation & Evaluation of Environmental Regulatory Requirements Guideline (SLB-QHSES008-

    G002).

    c) Hazardous Substance Storage Guideline (SLB-QHSE-S008-G003).

    d) Industrial Wastewater Discharge Sampling & Analysis Guideline (SLB-QHSE-S008-G004).

    e) Waste Minimization & Management Guideline (SLB-QHSE-S008-G005).

    f) Air Emissions Management Guideline (SLB-QHSE-S008-G006).

    g) Resource Conservation Guideline (SLB-QHSE-S008-G007).

    h) Wastewater Management Guideline (SLB-QHSE-S008-G008).

    i) Secondary Containment Test & Inspection Guideline (SLB-QHSE-S008-G010).

    j) Site Entry & Exit Assessment Guideline (SLB-QHSE-S008-G011).

    k) Broome Waste Management Plan.

    l) Broome Cyclone Emergency Response Management Plan.

    m) Broome Standard Operating procedures.

    n) Broome JSA/HARCs.

    o) Broome SOPs (See list below).

    p) Broome Emergency Response Plan.

    q) Broome Spill Prevention and Control Plan.

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    All persons working within the Site are required to complete a site induction and to comply with the

    requirements of the HSE Management system

    List of Broome Safe Operational Procedures (Not exhaustive)

    Forklift Re-fuelling.

    Fluid building.

    Fluid mixing procedure (WBM).

    Fluid mixing procedure (SBM).

    Fluid mixing procedure (Brine).

    Bulk liquid transfer (SBM) LMP to bulk road tanker.

    Bulk liquid transfer (SBM) Road tanker to rig support vessel.

    Bulk liquid transfer (SBM) Rig support vessel to road tanker.

    Bulk liquid transfer (SBM) Bulk road tanker to LMP.

    Bulk liquid transfer (Base Oil) LMP to bulk road tanker.

    Bulk liquid transfer (Base Oil) Road tanker to rig support vessel.

    Bulk liquid transfer (Base Oil) Rig support vessel to road tanker.

    Bulk liquid transfer (Base Oil) Bulk road tanker to LMP.

    Bulk liquid transfer (Brine) LMP to bulk road tanker.

    Bulk liquid transfer (Brine) Road tanker to rig support vessel.

    Bulk liquid transfer (Brine) Rig support vessel to road tanker.

    Bulk liquid transfer (Brine) Bulk road tanker to LMP.

    Bulk powder cutting procedure.

    Bulk powder transfer Cutting bottles to storage silo.

    Bulk powder transfer Storage silo to road tanker.

    Bulk powder transfer Road tanker to rig support vessel.

    Bulk powder transfer Break down of Equipment.

    5.1 Emergency Response Plan

    The Emergency Response Plan details the basic guidelines to be followed by M-I Australia personnel in

    the event of an incident occurring within facility. The Emergency Response Plan is designed to integrate

    with any other emergency management plans. In addition separate Cyclone Management plans and Spill

    Prevention and control plans are also in place.

    5.2 Spill Response Plan

    The M-I Australia Spill Response Plan is designed to help protect the environment in two ways:

    First, it provides the procedures / processes which will be used to prevent chemical spills, and

    waste releases; and

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    Second, should a spill or release occur, it describes the protocols for immediate coordination of

    necessary activities to minimize any harmful effects, including notification of appropriate

    government agencies as required under applicable federal, state, and local regulations.

    To handle a spill response effectively, the Spill Response Plan provides descriptions of the duties to be

    performed by facility personnel, procedures to be followed, available equipment, and available outside

    resources. See below Figure 5.2 (Spill Response Flowchart)

    Figure 5.2: Spill Response Flowchart

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    5.3 Cyclone Emergency Response Plan

    M-I Australia has a detailed Cyclone Emergency Response Plan that outlines its actions and

    responsibilities managing the risk posed by cyclones in the Kimberley Region, and specifically in the

    Broome Area. Pre-Cyclone actions include awareness training for all employees (including annual online

    refresher training) preparedness preparations in accordance with BOM guidelines, emergency contacts

    etc. Further details can be found in the M-I Australia Broome Cyclone emergency response plan.

    5.4 Noise Management

    Noise generated during operations shall be managed in accordance with Environmental Protection

    (Noise) Regulations 1997. Control measures in place to reduce noise to reasonably practicable levels

    include but not limited to the following;

    a) All equipment to be regularly maintained to ensure efficient operation in accordance with

    manufacturers recommendations.

    b) Pre-start checks and maintenance schedules shall be in place to ensure equipment performance is

    in accordance with requirements.

    c) Noise dampening equipment is fitted where required on equipment in accordance with National

    Code of Practice.

    d) Periodic Noise surveys are conducted to ensure exposure levels are with tolerance limits.

    5.5 Insect / Vermin Vector Management

    Insect vector management will focus around control of vermin, flies and mosquitos.

    Methods of Control

    Vector controls will focus on utilizing preventative methods to control/reduce or eliminate vector

    populations. Typical preventative measures are as follows:

    Habitat Control

    Removing or reducing areas where vectors can easily breed. Including, stagnant water removal, general

    waste to be stored in sealed covered bins with weekly removal, removal of retention pond contents in

    accordance with storm water management plans e.g. after cyclonic rainfall which may serve as

    mosquito breeding environments. Good management of used water can reduce areas of excessive

    vector incidence.

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    Chemical Control

    Insecticides, rodenticides and repellents may be used to control vectors. For example, insecticides can

    be applied to areas where insects may gather, and use of personal repellents can reduce incidence of

    insect bites and thus infection. The use of rodenticides i.e. baits may be used to help control vermin

    should they required.

    If vectors should reach levels where additional action is required a licensed pest controller will be called

    into initially assess and then implement plan to bring under control.

    5.6 Air Quality

    The Location Manager in conjunction with HSE will implement and maintain a Pollution Prevention Plan

    that includes: a current list of potential emissions and sources, regulatory requirements, procedures for

    meeting regulatory requirements, and training and record keeping requirements.

    The Location Manager will implement pollution prevention measures to minimize point source (e.g.

    chemical blending in tanks) and fugitive (e.g., yard roadway dust) air emissions. The Site Manager will

    consult with the APG Environmental Manager or the HSE representative for approved methods. For

    example, water is the only approved dust suppressant that may be applied to yards to control dust

    emissions.

    Typical Type of Emissions;

    1) Internal combustion engine - NOx, CO, particulates, SOx, VOCs

    Standard emissions from Diesel trucks, forklifts, and light vehicles - No more than

    would be experienced at any site, roadway or commercial precinct.

    2) Diesel storage tank - VOCs

    No more than would be experienced at any site or commercial precinct with diesel

    storage tank.

    3) Bulk plant particulates

    Rubber curtains on cutting operations to reduce initial created airborne particulates.

    Silo Vent particulate discharge is suppressed through use of reverse pulsating dust

    collection/filtration equipment

    5.7 Bushfire Management

    Prevention and management of bushfire are in accordance with FESA local instructions. The site is to

    maintain a one meter clear zone inside the perimeter to assist in reducing risk of fire damage in the

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    event of bush fire. Three sides of the lease area are easily accessible by Fire and emergency services at

    all times with the only side not accessible by emergency vehicles being bordered by the large

    warehouse. Behind the warehouse is a 1m exclusion zone and concrete drainage system which acts as

    emergency egress for staff that may be present inside the warehouse and unable to exit through

    normal operational doorways.

    5.8 Contractors and Carriers

    All contractors carrying at the Site are required to complete a full site induction and also required to

    operate under the facilitys Permit to Work System. All Contractors will be required to act in accordance

    with this EMP at all times while on Site.

    5.9 Implementation of Environmental Management Plan

    Management of M-I Australia operational activities that may have an impact upon environment is

    detailed in our Safe Operational Procedures and JSAs.

    5.9.1 Implementation

    To ensure effective implementation, M-I Australia:

    a) Communicate the OEMP to all staff, contractors and train personnel. Failure to involve all

    staff/contractors means that some may have little understanding of the issues and no

    ownership of the management measures that should be implemented.

    b) Make environmental considerations an integral part of the decision making process.

    c) Ensure that all contractors working on the site follow Safe Operational Procedures in place and

    comply with the OEMP.

    d) Periodically review operations where these procedures are implemented.

    e) Conduct periodic environmental management audits to ensure correct implementation of the

    OEMP.

    5.9.2 Environmental Monitoring and Review

    One of the central aspects of environment management plan implementation is monitoring the

    effectiveness of the procedures in reducing environmental impacts.

    A monitoring program will be in place so that procedures may be improved or new ones developed. A

    Monitoring well has been installed on site for collection of environmental data such as water quality.

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    Compliance to this OEMP shall be assessed based on the following performance factors:

    Internal (first and second-party) assessments against the requirements of this OEMP.

    Number and severity of environmental incidents, in absolute terms and normalized for

    exposure.

    Number of proactive environmental activities including near-incident and hazardous

    situation reports, communication meetings, inspections, etc.

    The internal audit assurance process applies to all risk levels;

    Where only Fundamental level controls apply, a second-party assessment shall be

    performed every 48 months.

    Where any Medium level controls apply a second-party assessment shall be performed every 36

    months.

    Where any High level controls apply, a second-party assessment shall be performed every

    24 months.

    5.10 Key Activities

    Below is a list of some key activities to be conducted at the facility and proposed management thereof:

    Activity: General Cargo Handling (other than dust generating activities, hazardous waste)

    Objective:

    Prevent uncontained release of solid waste.

    Relevant Activities:

    General Cargo Handling.

    Environmental Management Procedures:

    Ensure all products are clearly marked/labeled as to content.

    Ensure product is packaged in accordance with packaging guidelines including use of UV treated

    packaging.

    Ensure packaging materials are collected and properly disposed of.

    Conduct regular inspections of product / packaging in storage.

    Ensure that appropriate spill kits are available and regularly checked.

    Identify any damaged product and pallets and segregate in contained area. (Repalletize or

    return).

    Ensure all handling equipment (Forklifts etc) are adequately maintained in accordance with

    maintenance schedules.

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    Likely Pollutants:

    Solid waste/litter including plastic, chemical spill.

    Environment at Risk:

    Ground Surface (Note: Yard is sealed).

    Considerations:

    Conduct frequent inspection of storage and handling areas and handling equipment.

    Keep consistent and accurate records of inspection efforts.

    Storage structures designed to meet local and state regulatory requirements.

    Activity: Product Handling - Dust Generating Materials

    Objectives:

    Prevent emission of dust from dry bulk handling activities.

    Relevant Activities:

    Handling of dust generating materials such as barite and bentonite.

    Environmental Management Procedures:

    Cover storage and handling facilities where practicable.

    Adoption of dry break hoses to transfer bulk products from tanker to Silo.

    Process managed through SOP process.

    Scheduled maintenance and servicing of Silos, Dust collectors, hoses, PRVs etc. in accordance

    with Maintenance schedules and regulatory requirements.

    Use of certified Pressure Vessels.

    Utilize dust suppression mechanisms i.e. Dust Collectors.

    Utilize water sprays where practical.

    Minimize stockpile heights.

    Ensure use of sealed transport vehicles.

    Ensure hatches are covered when material handling is not being conducted.

    Conduct routine vacuum sweeping of handling areas.

    Clean up spills immediately.

    Likely Pollutants:

    Dust.

    Environment at Risk:

    Surface water and air.

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    Considerations:

    Provide training on handling and transport techniques for minimizing dust pollution.

    Develop routine inspection and maintenance program and keep records of activities.

    Activity: Solid Waste Handling

    Objectives:

    Prevent discharge of contaminants associated with solid waste handling.

    Relevant Activities:

    Solid waste collection.

    Solid waste handling.

    Solid waste disposal.

    Environmental Management Procedures:

    Covered waste storage facilities to prevent rainwater from carrying any potential contaminants

    off the site.

    Bunded areas to prevent contaminants entering the storm water system.

    Clearly mark facilities indicating what materials are acceptable for disposal.

    Provide separate receptacles for hazardous waste materials (e.g. paints and solvents).

    Provide receptacles for recyclable materials (e.g. aluminum, paper, including cardboard, glass).

    Provide suitable disposal facilities and procedures for quarantine waste.

    Ensure that receptacles are easily accessible.

    Monitor materials placed in receptacles, containers with solvents and paints, and other

    hazardous wastes.

    Empty waste receptacles frequently.

    Ensure all disposal areas are properly lighted to reduce chances of incorrect disposal.

    Identifying waste reception facilities.

    Identifying acceptable handling procedures.

    Encouraging recycling.

    Likely Pollutants:

    Litter including plastics.

    Land, surface water / groundwater.

    Activity: Waste Oil Management

    Objective:

    Prevent release of pollutants from the handling and storage of waste oil.

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    Relevant Activities:

    Storage, handling and transport of waste oil.

    Environmental Management Procedures:

    Cover all waste oil storage areas and ensure adequate ventilation in cases of spills and leaks.

    Ensure waste is contained in identified bunded area.

    Contain and properly dispose of leaks and spills from within bund through approved licensed

    waste disposal company.

    Seal joints and cracks ensure periodic inspection and integrity checks of bunded areas.

    Ensure all containers are securely loaded and tied down prior to transport.

    Avoid transfer of waste oil (from small containers or bunds into drums) in close proximity to

    drainage areas.

    Provide secondary containment for all active drums.

    Immediately contain and stop leaks and spills.

    Have spill response materials readily available, in strategic locations for use in any location.

    Clearly mark spill response materials.

    Likely Pollutants:

    Hydrocarbons (waste oil).

    Environment at Risk:

    Land, surface water, groundwater and marine environment.

    Activity: Chemical Storage and Handling

    Objective:

    Prevent release of pollutants from the handling and storage of chemicals in 205L drums /ISO

    tanks.

    Relevant Activities:

    Storage and handling of chemicals.

    Environmental Management Procedures:

    Cover all chemical storage areas.

    All liquid chemical storage areas to be bunded and sealed areas.

    The mixing area and dangerous goods storage areas will be bunded and covered to ensure

    containment in the unlikely event of a spill.

    Training provided in Hazardous Chemicals Management to all Material Handlers.

    Provide adequate ventilation in cases of spills and leaks.

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    Raise storage area above surrounding ground surface and berm to minimize seepage into

    surrounding areas and into the storm water system.

    Provide an impervious base in storage and handling areas to minimize releases to soils and

    groundwater.

    Seal joints and cracks.

    Protect storage area from vehicle accidents. (One way traffic management system).

    Restrict access to storage areas through the use of fencing or enclose storage areas.

    Provide flame-resistant containers where required.

    Use flame resistant locker for small quantities of materials.

    Ensure only compatible materials are stored together.

    Maintain, read and understand material safety data sheets (MSDS) for all chemicals.

    Minimize quantities of materials stored.

    Provide designated separate area for leaking hazardous products, which is:

    Covered and ventilated.

    Dead-end sumped to contain spills and leaks.

    Bermed to prevent spread of spills and leaks.

    Impervious based.

    Ensure all containers are marked and labeled properly.

    Ensure storage areas are clearly marked noting materials stored, emergency contacts, and spill

    cleanup procedures.

    Maintain copies of relevant MSDSs in a location near to but separate from chemical storage

    facility.

    Site Registration for Storage of Dangerous Goods in accordance with the Dangerous Goods

    Safety Act 2004 and Dangerous Goods Safety (Storage and Handling of Non Explosives)

    Regulations 2007.

    Three materials with dangerous goods classification are currently schedule to be stored on site

    i.e. 2 x synthetic bases oils and 1 x class 8 corrosive

    Likely Pollutants:

    Various chemicals including hazardous chemicals.

    Environment at Risk:

    Land, surface water, groundwater and marine environment.

    Activity: Building and Grounds Maintenance

    Objective:

    Prevent or reduce the discharge of pollutants from building and grounds maintenance.

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    Relevant Activities:

    Grounds maintenance.

    Herbicide/pesticide use.

    Building maintenance.

    Environmental Management Procedures:

    Minimize use of pesticides, herbicides, and fertilizers and use only as directed. Seek less

    harmful/toxic products.

    Provide adequate storage space for pesticides and herbicides, and ensure well ventilated.

    Exercise proper precautions when applying materials near water bodies or storm water systems.

    Properly dispose of green waste, wash water, sweepings, and sediments.

    Use "dry" cleaning techniques, such as sweeping, whenever possible.

    Incorporate landscaped areas that are pervious and will result in less runoff discharged from a

    site.

    Incorporate native vegetation to reduce irrigation, fertilizer, and pesticide needs.

    Likely Pollutants:

    Pesticides, herbicides, fertilizers.

    Paints, solvents, thinners and strippers.

    Litter including plastics.

    Environment at Risk:

    Land, surface water, groundwater and marine environment.

    Activity: Vehicle and Equipment Maintenance

    Objective:

    Prevent the discharge of pollutants during vehicle and equipment maintenance activities.

    Relevant Activities:

    Vehicle maintenance.

    Equipment maintenance.

    Vehicle equipment painting/stripping.

    Environmental Management Procedures:

    All such activities are to be conducted off site by third party contractor

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    Activity: Storm water, Erosion and Dust Control

    Objective:

    To control storm water movement in order to prevent or reduce soil erosion and the transfer of

    contaminated sediment to the marine environment.

    Relevant Activities:

    Repair of existing disturbed areas.

    Development of new areas.

    Control of runoff.

    Environmental Management Procedures:

    Identifying storm water pathways and volumes.

    Determining the extent of currently eroded areas.

    Identifying erosion problem areas.

    Develop an erosion control plan.

    Consider the use of structural storm water and erosion control devices including: earth dikes,

    drainage swales, interceptor dikes and swales, subsurface drains, silt fences, straw bale barriers,

    brush barriers, and gravel or stone filter berms.

    Plant native grasses, shrubs, or ground cover plants in drainage pathways to slow erosion.

    Incorporate storm water detention/retention to reduce peak runoff flows and to improve water

    quality.

    Plant native grasses, shrubs, or ground cover plants to slow erosion.

    Use mulch on disturbed soil.

    Provide cover of gravel, wood chips, or straw will help to minimize erosion processes.

    Consider use of netting or mats as a supplement to mulching.

    Control dust during dry weather by watering disturbed areas.

    Likely Pollutants:

    Contaminated sediment.

    Environment at Risk:

    Marine environment.

    6. ENVIRONMENTAL RISK REGISTER

    M-I Australia operations and activities, by their nature, have the potential to impact upon one or more

    aspects of the natural or social environment. The risk register describes activities undertaken at the

    facility, identifies the potential significant environmental and social impacts, and summarizes

    operational controls currently in place to mitigate these impacts.

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    6.1 Definitions

    Air Emissions

    Hazardous substances, including gases or particulates for which M-I Australia and associated

    contractors are responsible released into the air. Hazardous air emission sources at M-I Australia sites

    include, but are not limited to: bulk powder plants, engine exhausts, and some sand blasting operations.

    Dangerous Goods

    Dangerous goods are substances or articles that, because of their physical, chemical (physicochemical)

    or acute toxicity properties, present an immediate hazard to people, property or the environment. The

    criteria used to determine whether substances are classified as dangerous goods are contained in the

    Regulations which refer to the Australian Dangerous Goods Code (ADG Code) (available at

    www.ntc.gov.au). This is closely aligned with the criteria of the United Nations Recommendations on

    the Transport of Dangerous Goods - Model Regulations.

    Discharges

    Release of substances into the environment: Generally refers to the release of liquids into a body of

    water.

    Emissions

    Release of substances into the environment: Generally refers to the release of gases, odours, or

    particulates (dust) into the air.

    Environment (OGP)

    The surroundings and conditions in which a company or individual operates or which it may affect,

    including living systems (human and other) therein.

    Environmental Impact Assessment (OGP)

    A formal, written, technical evaluation of potential effects on the environment (atmosphere, water,

    land, plants, and animals), of a particular event or activity.

    Hazardous Waste (M-I Australia Recognized)

    Any waste that is classified as hazardous (according to government regulations) or otherwise classified

    as a potential hazard to human health or the environment.

    Hydrocarbon Fuels

    Fossil fuels that are combusted for energy or transportation, including petrol, gasoline, diesel, oils -

    heating, generators, engines and kerosene.

    Leak

    A leak is a systemic or chronic undesired loss of primary containment of oil, oil products, chemicals,

    solvents, and/or hazardous substances. A leak is often small with no immediate damage to the

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    environment. It is the cumulative effect of many leaks over time that has the potential to damage the

    environment.

    Performance Indicator (OGP)

    A specific measure to describe management, operational process or performance.

    Prevention of Pollution

    Use of processes, practices, materials or products that avoid, reduce or control pollution, including

    recycling, treatment, process/material changes, control mechanisms, efficient use of resources.

    Responsible Disposal (OGP)

    The deposition of waste, onto land or into water, using methods appropriate for a given situation.

    Disposal methods include: landfill, burial, surface discharge, land-spreading or land-farming, and

    underground injection.

    Spill (OGP)

    Any loss of containment that reaches the environment, irrespective of quantity recovered.

    Waste (OGP)

    Any material, (solid, liquid, or gas), which is introduced into the work location as a product of the work

    but which fulfils no further useful purpose, at that location.

    Waste Minimization and Management

    A system designed to achieve waste reduction, reuse, reclamation, recycling, and responsible disposal.

    Wastewater Discharges Industrial

    Industrial waste water is related to industrial processes such as: manufacturing, cleaning, equipment

    testing, chemical blending, mechanical, electronic operations; includes the runoff and leachate from

    areas that receive pollutants such as wash bays, fuel and chemical storage areas; includes all other

    wastewater that is not defined as domestic/sanitary wastewater or storm water.

    Wastewater Discharges Sanitary or Domestic

    Domestic or sanitary water is related to dwellings, camps and business buildings; includes kitchen,

    bathroom (sewage) and laundry wastewater; sometimes sub-classified as grey water (from showers and

    kitchens) and black water (from toilets).

    6.2 Environmental Events

    Reporting of environmental events, inspections, assessments and audits is fully integrated into

    QUEST, the M-I Australia QHSE data capture and reporting system. All reporting shall initially comply

    with all local regulatory and BrPA requirements. In addition Company Standards including SLB-QHSE-

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    S002 or SLB-QHSE-S007 shall be met.

    M-I Australia recognizes three types of reportable spills: those involving hazardous substances, crude oil

    and produced water. For the purposes of internal M-I Australia reporting, refined petroleum products

    such as motor oil, kerosene, and petrol are to be categorized as hazardous. The severities of

    environmental incidents are defined in the table below.

    Table 6.2: Environmental Incident Severity Classification

    6.6.6.6.3333 Environmental Risks of Significance to Environmental Risks of Significance to Environmental Risks of Significance to Environmental Risks of Significance to MMMM----IIII Australia Australia Australia Australia Operations Operations Operations Operations

    The below table is indicative. It is non exhaustive list of potential activities that may pose a significant

    risk to the environment or the impacts that may arise, or of the controls that may be implemented to

    avoid, remedy or mitigate environmental risks.

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    Table 6.3: Environmental Risk Related Activities

    7. REFERENCES

    SLB Event reporting and Management (SLB-QHSE-S002)

    SLB Auditing (SLB-QHSE-007)

    SLB Environmental Standard (SLB-QHSE-S008)

    SLB Environmental B.O.O.K

    BPA Environmental Management Plan 2013

    SLB QHSE Policy