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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?
Prepared by: Richard Taylor
BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP
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Approved by: James Cobb Issued: 10th Mar 2014
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)
Prepared by: Richard Taylor
BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP
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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
Prepared by: Richard Taylor
BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP
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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)
Prepared by: Richard Taylor
BROOME Lot E3BROOME Lot E3BROOME Lot E3BROOME Lot E3 Ref: BROOME OEMP
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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
Prepared by: Richard Taylor
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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