REVISIONS, DISTRIBUTION AND CONSULTATION

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25585-500-G01-GHX-00094 Page 2 of 83 Revision 002

Commissioning Environmental Management Plan

REVISIONS, DISTRIBUTION AND CONSULTATION

The development of this Commissioning Environmental Management Plan (CEMP) has

been compiled, revised and distributed in the consultation of internal and external

stakeholders, including:

Revision Stakeholder In consultation of Date

000 QGC QGC 26.08.2013

001 QGC QGC 29.10.2013

002

This procedure shall be revised and amended in accordance with the consultation and

collaboration requirements of relevant Stakeholders. This plan is intended to be a working

document and will be subject to periodic audit and review. Amendment will only be made to

reflect changes in project requirements or to correct any disparity identified during project

review or auditing.

Any comments, complaints and improvements regarding this document should be forwarded

to this CEMP’s Sponsor. If the text or body of this CEMP is required to be updated at any

stage during the operations, a revised copy will be submitted relevant agencies with a

consultation or approval role.





TABLE OF CONTECTS

1. INTRODUCTION AND SCOPE ..................................................................... 12

1.1. PROJECT BACKGROUND ........................................................................... 14

1.2. APPROVALS, PERMITS AND LEGISLATION .............................................. 15

1.2.1. Environmental Authority ................................................................................ 15

1.2.2. Other permits ................................................................................................. 15

1.2.3. Legislative Framework, Industry Standards and Guidelines ......................... 15

1.3. RELATED DOCUMENTATION ..................................................................... 15

1.4. PLAN STRUCTURE ...................................................................................... 16

2. DESCRIPTION OF LNG PLANT PROCESS ................................................ 17

2.1. LNG PLANT PROCESS ................................................................................ 17

2.1.1. Composition of gas ........................................................................................ 18

2.1.2. Inlet Separation (Unit 11) .............................................................................. 18

2.1.3. Acid Gas Removal (Unit 12) .......................................................................... 18

2.1.4. Dehydration (Unit 13) .................................................................................... 19

2.1.5. Mercury Removal (Unit 13)............................................................................ 19

2.1.6. Liquefaction (Units 14, 15 & 16) .................................................................... 19

2.1.7. LNG Storage (Unit 24) ................................................................................... 19

2.1.8. LNG Jetty and ship loading ........................................................................... 20

2.1.9. Utilities ........................................................................................................... 20

2.1.9.1. Flare and Relief System (Unit 19) ............................................................ 20

2.1.9.2. Diesel Storage and Transfer .................................................................... 21

2.1.9.3. Power Generation .................................................................................... 21

2.1.9.4. Plant and Instrument Air (Unit 35) and Nitrogen (Unit 39)........................ 21

2.1.9.5. Firewater Systems (Units 33) ................................................................... 22

2.1.9.6. Fuel Gas ................................................................................................... 22

2.1.9.7. Hot Oil System (Unit 34) .......................................................................... 22





2.1.9.8. Refrigerant Storage .................................................................................. 23

2.2. ASSOCIATED INFRASTRUCTURE ............................................................. 23

2.2.1. Water Supply, Management and Storage ..................................................... 23

2.2.1.1. Potable Water .......................................................................................... 23

2.2.1.2. Water treatment system (Unit 36) ............................................................ 23

2.2.1.3. Stormwater Management (non-process areas) ........................................ 23

2.2.2. Waste water and effluent management ......................................................... 24

2.2.3. Amine and Hot Oil Drainage .......................................................................... 24

2.3. OTHER CSU ACTIVITY ................................................................................ 25

2.3.1. Lube oil flushing ............................................................................................ 25

2.3.2. Chemical cleaning ......................................................................................... 25

2.3.3. Degreasing of the Acid Gas Removal Unit .................................................... 25

2.3.4. Materials Storage and Handling .................................................................... 25

2.3.5. Waste Management ...................................................................................... 26

2.3.6. Dangerous Goods and Hazardous Substance Handling ............................... 27

2.4. CONSTRUCTION PHASE ACTIVITIES DURING COMMISSIONING .......... 28

3. OVERALL ENVIRONMENTAL MANAGEMENT APPROACH ..................... 30

3.1. PERFORMANCE CRITERIA ......................................................................... 30

3.2. ENVIRONMENTAL POLICIES ...................................................................... 30

3.2.1. QGC Environmental Policy ............................................................................ 30

3.2.2. Bechtel Environmental Policy ........................................................................ 30

4. ENVIRONMENTAL CONDITIONS AND VALUES ........................................ 31

4.1. CLIMATIC CONDITIONS .............................................................................. 31

4.2. SENSITIVE RECEPTORS (NOISE, VIBRATION AND AIR QUALITY) ........ 31

4.3. VISUAL (LIGHTING) ..................................................................................... 33

4.4. ECOLOGY ..................................................................................................... 33





4.5. GROUNDWATER ......................................................................................... 35

4.6. SURFACE WATER ....................................................................................... 35

4.7. MARINE WATER .......................................................................................... 35

5. CSU ACTIVITIES, POTENTIAL ENVIRONMENTAL IMPACTS AND ASSOCIATED MANAGEMENT ............................................................................... 36

5.1. AIR QUALITY MANAGEMENT ..................................................................... 39

5.1.1. Performance criteria ...................................................................................... 40

5.1.2. Point Source Air Emissions ........................................................................... 42

5.1.2.1. CSU Flaring .............................................................................................. 42

5.1.2.2. CSU of gas turbines, hot oil heater and regeneration gas heater ............ 43

5.1.2.3. AGRU ....................................................................................................... 46

5.1.3. Fugitive Emissions ........................................................................................ 46

5.2. NOISE ........................................................................................................... 48


5.2.2. Point Source Noise emissions ....................................................................... 48

5.2.2.1. Flaring ...................................................................................................... 48

5.2.2.2. Pipe air blowing ........................................................................................ 50

5.3. WATER AND WASTEWATER MANAGEMENT ........................................... 51


5.3.2. Stormwater from process areas and discharge from the water treatment facility 53

5.3.3. Sewage Effluent ............................................................................................ 56

5.3.4. Stormwater (non-process area) ..................................................................... 56

5.3.5. Groundwater .................................................................................................. 57

5.3.6. Loading of LNG carriers at jetty ..................................................................... 57

5.4. DANGEROUS GOODS AND HAZARDOUS SUBSTANCES ....................... 58

5.4.1. Hazardous Substances Management and Storage ....................................... 59

5.4.2. Spill Management .......................................................................................... 61





5.4.2.1. Spill Response ......................................................................................... 61

5.4.2.2. Spill Cleanup Actions ............................................................................... 62

5.5. WASTE MANAGEMENT ............................................................................... 63

5.5.1. Collection and Handling ................................................................................ 64

5.5.2. Storage and Handling .................................................................................... 64

5.5.3. Transportation of Waste ................................................................................ 64

5.5.4. Monitoring of Waste ...................................................................................... 64

5.5.4.1. Waste Tracking ........................................................................................ 65

5.5.4.2. Waste Disposal ........................................................................................ 66

5.5.5. Non-hazardous Wastes ................................................................................. 66

5.5.6. Hazardous Waste .......................................................................................... 66

5.6. LIGHTING ..................................................................................................... 67

5.7. PESTS AND MOSQUITO’S .......................................................................... 68

5.8. FLORA AND FAUNA MANAGEMENT .......................................................... 68

6. GENERAL ENVIRONMENTAL MANAGEMENT .......................................... 69

6.1. ENVIRONMENTAL EMERGENCY PREPAREDNESS ................................. 69

6.2. INTEGRATED CONTROL AND SAFETY SYSTEM ..................................... 69

6.3. ENVIRONMENTAL INCIDENTS ................................................................... 71

6.4. JOB HAZARD ANALYSIS ............................................................................. 72

6.4.1. Site Environmental Plan ................................................................................ 72

6.5. STRUCTURE AND RESPONSIBILITIES ...................................................... 72

6.5.1. Queensland Gas Company (QGC)................................................................ 73

6.5.2. Bechtel .......................................................................................................... 73

6.5.2.1. Senior Project Manager ........................................................................... 74

6.5.2.2. Site Manager ............................................................................................ 74

6.5.2.3. Health, Safety, Security and Environmental Manager ............................. 74





6.5.2.4. Environmental Services Manager ............................................................ 74

6.5.2.5. Environmental Inspectors ......................................................................... 75

7. PROGRAMMES AND PROCEDURES ......................................................... 76

7.1. AWARENESS, TRAINING AND COMPETENCY ......................................... 76

7.2. COMMUNICATIONS ..................................................................................... 76

8. ENVIRONMENTAL PROCEDURES AND FORMS ...................................... 77

8.1. ENVIRONMENTAL INSPECTION ................................................................. 77

8.2. ENVIRONMENTAL AUDITING ..................................................................... 78

8.3. NON-CONFORMITY, INVESTIGATION AND PREVENTIVE ACTION ........ 78

8.4. DOCUMENT CONTROL AND RECORDS .................................................... 78

8.5. CONTINUAL IMPROVEMENT ...................................................................... 79

8.6. REVIEW ........................................................................................................ 79

APPENDIX A - LEGISLATION, INDUSTRY STANDARDS AND GUIDELINES ..... 80

APPENDIX B - ENVIRONMENTAL POLICIES ....................................................... 82

QGC HSSE POLICY ................................................................................................ 82

BECHTEL ENVIRONMENTAL POLICY .................................................................. 83





LIST OF ACRONYMS

oC Degrees Celsius

ADWG Australian Drinking Water Guidelines

AGRU Acid Gas Removal Unit

ALARP As low as reasonable possible

AS Australian Standard

BOG Blow Off Gas

CH4 Methane (gas)

C2H4 Ethylene (gas)

C2H6 Ethane

C3H8 Propane (gas)

CECP Construction Environmental Control Plan

CEMP Commissioning Environmental Management Plan

CO2 Carbon dioxide (gas)

CPI Corrugated Plate Inceptor

CSG Coal Seam Gas

CSU Commissioning and Start-up

DAF Dissolved Air Floatation Unit

dBA A-weighted sound levels in Decibels

DEHP Department of Environment and Heritage Protection

DG&HS Dangerous goods and hazardous substances

EA Environmental Authority

EDI Electro-deionisation

EH Environmental Harm

EP Act Environmental Protection Act

EPBC Act Environment Protection and Biodiversity Conservation Act

EPP Waste Environmental Protection Policy (Waste)

ERA Environmentally Relevant Activities

EIS Environmental Impact Assessment

GAWB Gladstone Area Water Board

GBRCMP Great Barrier Reef Coast Marine Park

GBRWHA Great Barrier Reef World Heritage Area

GPC Gladstone Port Corporation

GTG Gas Turbine Generator

H2O Water

H2S Hydrogen Sulphide





Hg+ Mercury

HSSE Health, Safety, Security and Environment

JHA Job Hazard Analysis

ICSS Integrated Control and Safety System

ISBL Inside battery limits

LNG Liquefied Natural Gas

MNES Matters of National Environmental Significance

N2 Nitrogen (gas)

NEPM Air National Environmental Protection Measure

NOx Oxides of Nitrogen

NRU Nitrogen Rejection Units

PASCS Process Area Spill Containment Sump

PIG Pipeline Inspection Gauge

PFL Petroleum Facility Licence

PM Particulate matter

QCLNG Queensland Curtis Liquefied Natural Gas

QGC Queensland Gas Company

RO Reverse osmosis

sEIS Supplementary Environmental Impact Statement

SEPs Site Environmental Plans

SimOp Simultaneous operation

TCCC Time of care, custody and control

TCF Temporary camp facility

VOCs Volatile organic compounds

WHR Waste Heat Recovery

WMS Work Method Statement





DEFINITIONS

Administering

Authority

An authority with legislative jurisdiction

Best Practice

Environmental

Management

The management of the activity to achieve an ongoing minimisation of the

activity’s environmental harm through cost-effective measures assessed

against the measures currently used nationally and internationally for the

activity (s21, EP Act 1994)

Contamination incident Contamination incident means an incident involving contamination of the

environment, that the administering authority is satisfied has caused or is

likely to cause serious or material environmental harm.

Control Measure Control measure means a device, equipment, structure, or management

strategy used to prevent or control the release of a contaminant or waste to

the environment. Examples include:

• an acoustic enclosure

• a bund around a storage pond

• a release or overflow valve on machinery

• a strategy for operating a furnace in a way that achieves combustion of a

contaminant at a particular oxygen level

Dangerous Goods Dangerous goods class means the class allocated to dangerous goods under

the seventh edition of the ‘Australian Code for the Transport of Dangerous

Goods by Road and Rail’.

Environmental

Aspect

An element of the surrounding environment requiring specific environmental

management and/or consideration.

Environmental Harm Environmental harm is any adverse effect, or potential adverse effect

(whether temporary or permanent and of whatever magnitude, duration or

frequency) on an environmental value, and includes environmental nuisance.

Environmental

Nuisance

Environmental nuisance is unreasonable interference or

likely interference with an environmental value caused by—

(a) aerosols, fumes, light, noise, odour, particles or smoke; or

(b) an unhealthy, offensive or unsightly condition because of contamination;

or

(c) another way prescribed by regulation.





Environmental Value Environmental Value is a quality or physical characteristic of the environment

that is conducive to ecological health, public amenity or safety, or declared to

be a value under legislation.

Licensed Waste

Transporter

Approved waste transporter means a person who removes, collects or

transports waste under an approval from a local government under section

369A of the EP Act 1994.

Monitoring Monitoring, in relation to monitoring the impact of an activity on the receiving

environment, includes analysing, assessing, examining, inspecting,

measuring, modeling or reporting any of the following—

(a) the quantity, quality, characteristics, timing and variability of the release of

the contaminant;

(b) the effectiveness of control measures;

(c) characteristics of, and impact on, the receiving environment;

(d) the effectiveness of remedial or rehabilitation measures.

Regulated Waste Regulated waste means regulated waste within the meaning of the

Environmental Protection Regulation 2008.

Release Release, of a contaminant into the environment, includes - Schedule 4 of EP

Act 1994:

(a) to deposit, discharge, emit or disturb the contaminant; and

(b) to cause or allow the contaminant to be deposited, discharged emitted or disturbed; and

(c) to fail to prevent the contaminant from being deposited, discharged, emitted or disturbed; and

(d) to allow the contaminant to escape; and

(e) to fail to prevent the contaminant from escaping.

Sensitive Receptor Sensitive Receptor means a sensitive receptor under any relevant

environmental protection policies.

Spill A minor spill is defined as a spill where:

The amount or nature of the released/potentially released substance cannot cause serious harm to community health or the environment.

A major spill is defined as a spill where:

The amount or toxic nature of the substances released / potentially released can cause serious harm to community health or the environment

Trackable waste Trackable waste is as per the definition of Section 17 of the Environmental Protection (Waste Management) Regulation 2000.





1. Introduction and Scope

This Commissioning Environmental Management Plan (CEMP) addresses the potential

environmental impacts associated with the Commissioning and Start-Up (CSU) of the

QCLNG plant, and provides guidance for the mitigation and management of these. The

CEMP is focused on the CSU activities that Bechtel are undertaking and will serve its

purpose up to the completion of the commissioning process, scheduled for 2015, when the

entire facility (including Train 1 and Train 2) is taken over by QGC.

The existing Construction Environmental Control Plan (CECP) (25566-100-G01-GHX-00044)

remains valid (for construction activities) and runs concurrently with this CEMP (for CSU

activities), until Transfer of Care, Custody and Control (TCCC). At this point, the QCLNG

facility will be formally handed over, by Bechtel, to the QGC Operational Team. The Division

of Responsibilities (DOR) is detailed in Section 6 of this document.

The scope of this CEMP extends from the battery limit downstream of the Pipeline

Inspection Gauge (PIG) receiver and filter coalescer to the LNG loading arms on the loading

dock at the jetty. However:

Hydrostatic testing of the LNG tanks has been classed as a separate commissioning-

based activity and is covered under the QCLNG Uptake and Discharge of LNG Tank

Hydrotest Water process procedure (25585-500-GPP-GHX-10037);

Management of plant pipework and firewater hydrotesting is covered under the QCLNG

Hydrotest & Pipe Flushing Water - Plant process procedure (25585-500-GPP-GHX-

10039); and

Site pneumatic testing and any associated environmental noise impacts fall under the

remit and timeline of construction so will be managed under the CECP.

The objective of this management plan is to:

Describe the proposed process for CSU, particularly in the context of the environment;

Outline the associated environmental values that have the potential to be impacted by

commissioning activities;

Present the potential environmental impacts from the CSU activities;





Consider the environmental issues associated with the startup of Train 1 whilst Train 2 is

still in construction;

Identify relevant environmental objectives and performance criteria;

Present the relevant legislation, guidelines and other documents; and

Prescribe the environmental mitigation, management and monitoring that will be adopted

for the CSU process.

Note that this document serves as the overarching environmental management plan. As

required, additional internal procedures (such as activity specific procedures, Job Hazard

Analysis, Work Method Statements) will be developed as part of the ongoing assessment

and management of environmental risk. Ongoing management also features routine

environmental inspections and audits, recording incidents and training as discussed in

section 6 to 8.

For clarity, the stages discussed in this plan are defined as follows:

Mechanical completion – point when construction activities associated with the

installation of the facility (including, piping, instrumentation, electrical, and buildings) are

complete and in accordance to process specifications and drawings.

Pre-commissioning – includes the checking, cleaning and testing of the installed

permanent plant and equipment prior to CSU. Activities can include instrument

functional checks, cleaning of vessel and piping systems, nitrogen purging and leak

testing.

Commissioning – includes verification of functional operation through a structured

program of calibration, testing and certification to ensure all equipment is completed and

ready to introduce process / commissioning fluids. Also includes the verification that

support facilities can be started up and will operate within the design parameters and

specifications.

Start-up – once all commissioning test have identified the facility is fit to receive process

fluids and feed gas.

Operation – all necessary systems, resources and requirements to operate the facility

are operational and LNG is produced.





1.1. Project Background

Queensland Gas Company (QGC), a wholly-owned subsidiary of British Gas Group PLC

(BG Group), is developing a world-scale, integrated liquefied natural gas project in

Queensland, known as the QCLNG project. The project will be one of Australia’s largest

capital projects and will supply a nominal 4.23million metric tonnes per annum (mtpa) of

LNG per Train.

The overall QCLNG project consists of the following components:

Coal seam gas (CSG) field development and supporting infrastructure in the Surat Basin

(Gas Field Component. Note: not part of Bechtel’s scope);

A network of underground pipelines, including gas and water collection pipelines in the

Gas Field Component, and 380 km of underground gas transmission pipeline (Export

Pipeline) from the Gas Field to an LNG Facility. (Pipeline Component. Note: not part of

Bechtel’s scope);

A gas liquefaction facility on Curtis Island, adjacent to Gladstone, initially comprising two

processing units, or “trains”. This component also includes an export jetty and other

supporting infrastructure (LNG Component. Note – within Bechtel’s scope);

Access channels for shipping vessels (Swing Basin and Channel. Note: not part of

Bechtel’s scope); and

LNG shipping operations to load the LNG and export it to global markets (Note: Shipping

Operations are not part of Bechtel’s scope).

For a full description of the project refer to the QCLNG draft Environmental Impact

Statements (EIS) and supplementary EIS (sEIS), which can be accessed at

www.qgc.com.au/environment/environmental-impact-management . The project component

relevant to this management plan is the gas liquefaction facility.





1.2. Approvals, permits and legislation

1.2.1. Environmental Authority The QCLNG facility is defined as a petroleum facility under the Petroleum and Gas

(Production and Safety) Act 2004, and as such, required a petroleum facility license (PFL) in

order for its construction and operation. Under the guide of Chapter 5 in the Queensland

state Environmental Protection Act (EP Act) 1994, it is a legislative requirement for

petroleum activities to be issued with an Environmental Authority (EA). An application for a

PFL was lodged by QGC to DEHP, previously known as the Department of Environment and

Resource Management (DERM), and approval was granted under Environmental Authority

Permit Number: EPPG00711513.

Within this EA, there are conditions that are applicable to the CSU of the project and as

such, this is the key approval that any activities will be delivered within. The recent update is

effective 18 October 2013.

1.2.2. Other permits Other site specific permits and their respective conditions have been reviewed to identify

conditions which are relevant to CSU activities. The prescribed tidal works permit for the

LNG Jetty (DA 479/2011) and for Tidal Area Infrastructure (DA 239/2010) have been

identified as most applicable, and while they have not been discussed in detail within this

document, their requirements and responsibilities are not excluded from the overall delivery

of CSU. The majority of other permit conditions relate to construction activities and are

included within the project’s CECP, process procedures and/or activity based management

plans. Reference will be made to these during CSU as required.

1.2.3. Legislative Framework, Industry Standards and Guidelines There are many Local, State and Commonwealth legislative requirements, as well as

international agreements which are relevant to activities of project construction,

commissioning and operation. Some of these are presented in Appendix A. There are also

a number of industry standards, codes and guidelines relevant to the commissioning phase.

Bechtel Core Process 403: Legal and Other Requirements details Bechtel’s commitment to

adhere to all legal and non-legal responsibilities and obligations.

1.3. Related Documentation

This CEMP is supported by a suite of environmental planning and management instruments

that have been implemented during the project to manage environmental impacts, including:





The QCLNG Environmental Impact Statement (EIS) and Supplementary information to

the EIS;

The QCLNG Environmental Services Manual;

Sub-management Plans (Attachments); and

The QCLNG Curtis Island Construction Environmental Control Plan.

As a Bechtel project, the commitments and obligations included in this CEMP and other

associated documents are supported by the Bechtel Core Processes and the Environmental

Services Manual.

1.4. Plan Structure

This CEMP is structured as follows:

Section 1 Introduction which includes the document objectives, project background and

relevant documentation.

Section 2 Description of LNG plant process which describes the relevant commissioning

activities and their location.

Section 3 Overall management approach which presents the performance criteria and

policy context.

Section 4 Environmental conditions and values.

Section 5 CSU activities, potential environmental impacts and associated management

Section 6 General environmental management including the project protocols for work

planning, incidents, and emergencies.

Section 7 Programmes and procedures.

Section 8 Environmental procedures and forms.





2. Description of LNG Plant Process

This section outlines the LNG plant process to give context to the CSU activities and

potential environmental impacts that will be monitored and managed. For ease of

referencing, the process units have been numbered (Unit 11 to 39) which will allow clear

comparison with other related plans and documents.

2.1. LNG Plant Process

Using the ConocoPhillips Optimized Cascade process (Figure 1), CSG will be processed

into LNG. In summary, gas is cooled to a liquid state (through pressure reduction, acid gas

removal, dehydration and mercury removal) so it is easier and safer to transport. Essentially

each train will use scrubbers and filters to remove the impurities from the CSG including N2

and CO2, and utilise three compressor and exchanger sets to chill the gas to -162oC. A 3D

representation is shown in Figure 2.

Figure 1: Schematic of the ConocoPhillips Optimized Cascade® Process





Figure 2: 3D representation of the QCLNG processing plant

2.1.1. Composition of gas The typical composition of the CSG from the feed wells is mainly methane with traces of

nitrogen, carbon dioxide, ethane, water, hydrogen sulphide, mercaptans (total), and sulphur

(total).

2.1.2. Inlet Separation (Unit 11) After delivery to site, the gas enters the pre-treatment component of the facility, including the

feed gas inlet and metering systems. The primary function of Unit 11 is metering, heating

and pressure reduction of the feed gas.

2.1.3. Acid Gas Removal (Unit 12) Once water separation occurs, CSG is fed into the acid gas removal unit (AGRU) where

contaminants are first filtered and then removed within the CO2 absorber. Utilising an

activated Diglycolamine (amine) solvent solution, the regenerating amine system removes

CO2 (<1 mol% concentration) to prevent potential freezing issues. Hydrogen sulphide

(<0.15ppmv) is also removed to ensure LNG sulphur specifications are met. A completely

enclosed amine drain collection system is utilised to collect amine waste and allow storage

of waste prior to the safe removal from site as required.





2.1.4. Dehydration (Unit 13) The treated gas leaving the AGRU is chilled prior to entering the dryer inlet separator for

separation of CO2, H2O and trace hydrocarbons. Dehydration is facilitated within the

molecular sieve dehydrators, where the final traces of H2O vapour are removed (<1ppm) to

prohibit ice particles forming in the gas stream while it passes through downstream units.

2.1.5. Mercury Removal (Unit 13) This final gas treatment step removes any trace amounts of mercury (Hg+), preventing

potential corrosion damage to downstream heat exchangers. To aid Hg+ absorption, gas is

passed through sulphur-impregnated activated carbon beds. Further filtration of gas particles

is conducted before entering the refrigeration and liquefaction units. As the activated carbon

beds have a design life of 3 years (mercury-content dependant) these will only need to be

removed and managed as a regulated waste stream (if there is mercury present) later in the

plant operational phase. Defrost gas will be provided from the dry feed gas downstream of

Unit 13 or other suitable sources (e.g. methane system), and will regenerated to the

liquefaction plant.

2.1.6. Liquefaction (Units 14, 15 & 16) Through a combined process of heat exchange and pressure reduction with refrigerants, dry

gas is liquefied into LNG. This system of cascade and compression consists of three (3)

refrigeration services, namely propane (C3H8), ethylene (C2H4) and methane. Each unit is

driven by two independent General Electric LM2500+ G4 gas turbine refrigerant

compressors and equipped with individual suction drums and anti-surge controls. There is

also a Waste Heat Recovery (WHR) system affixed to the CH4 compressor unit for the

recovery of gas turbine exhaust heat.

After the gas passes through dry gas filters, it is partially cooled in the C3H8 refrigeration

system, with the heat removed to the atmosphere from numerous extraction fans. The cool

gas then enters the C2H4 refrigeration system for further cooling and condensed by heat

exchangers in the C2H4 cold box. Lastly, the gas enters the CH4 refrigeration system for final

cooling to ≈ 160oC and N2 removal through the cryogenic nitrogen rejection unit (NRU) and

cold box.

2.1.7. LNG Storage (Unit 24) Two large cryogenic LNG storage tanks, each with a capacity of 140,000m3, will store the

LNG produced by Train 1 and Train 2. Each tank, built with double-wall concrete structure

with the internal walls having sheets of 9% nickel alloy welded together. Each LNG storage





tank will be equipped with loading pumps, level gauges, level transmitters, relief valves,

vents, temperature elements, and other basic instrumentation necessary for the appropriate

monitoring and management of the facility components.

To ensure complete enclosure of the LNG tanks, each tank will undergo hydrotesting to

approximately 60% of the total volume with 88.3 mega litres (ML) of water. The procedure

for hydrotesting is outlined in the Uptake and Discharge of LNG Tank Hydrotest Water

process procedure (25585-500-GPP-GHX-10037).

2.1.8. LNG Jetty and ship loading From the LNG storage tanks, the product will be pumped to the jetty along a network of

piping, where it is then transferred to the LNG ship via several loading arms. The LNG jetty

is designed for the berthing, mooring, and handling of LNG carriers of up to 220,000m3

capacity, and includes:

A loading platform with four 16” LNG loading arms (2 liquid, 1 vapor, and 1 hybrid) to

achieve minimum 12,000 m3/hr;

Four breasting dolphins, six mooring dolphins and interconnecting catwalks;

An access trestle with roadway and pipe-way to the shore; and

Marine terminal building platform.

As a safety precaution, the vapour return arm will capture any displaced gas from the ship

tanks and any flashed / vaporised gas from the ship loading, and return it to the LNG tanks.

This gas will undergo further compression within the boil off gas (BOG) system and the

Wet/Dry Gas Flare K.O Drum, where it will be returned to the liquefaction system for

processing. During CSU and initial operational activities, it is anticipated that excess gas

during ship loading may be produced and will need to follow the path to the BOG and re-

liquefaction systems. However, given the variations in the initial CSU and operational

activities, there may be a need to discharge the surplus gas via the flare and relief system.

2.1.9. Utilities Ancillary utilities necessary for the CSU phase, and furthermore the operations, of the facility

are detailed below.

2.1.9.1. Flare and Relief System (Unit 19) A system of three (3) separate flare systems will be implemented to cater for the release of

H2O vapour and gas releases associated with the production processes. The flare system

features a co-located Wet and Dry Gas Flare stack and a Marine Flare stack. These flare





systems are a primary safety feature of the LNG facility collecting and disposing of

hydrocarbon-contaminated streams typically released during start-up, shutdown and

emergency conditions. Increased flaring is a normal and expected part of the commissioning

and start-up of the plant and is required to get a better operational environmental outcome.

The Wet Gas Flare will release any waste hydrocarbon streams possibly saturated with H2O

vapour and/or free liquid hydrocarbons. The Dry Gas Flare system will provide a system of

release of cryogenic hydrocarbons (vapour or liquid) from the process trains.

The Marine Flare will dispose of any flashed LNG vapours generated from the LNG storage

tanks and the BOG system, as well as during the loading of the LNG transport ships. BOG

compression is significant in limiting the amount of flare required during plant operation and

the LNG loading process.

2.1.9.2. Diesel Storage and Transfer Diesel, for site wide usage, will be bunkered to the facility as per the Diesel Delivery

Execution Plan (25585-500-G01-GCX-10002) and will be stored in the Fuel Farm. Diesel will

be transferred, via underground piping from the fuel farm, to the Diesel Oil Transfer Pump

and onward to the associated day tanks servicing the Stand-by Diesel Generators, the

Firewater Pumps and the Start-up/Stand-by Air Compressors.

2.1.9.3. Power Generation A standby generator system, consisting of three (3) Construction Power Diesel Generator

Black Start packages and one (1) Standby Diesel Generator Marine Terminal Building

Package, will supply power during system outages. The Construction Power Diesel

Generators are designed with bi-fuel conversion (diesel and LP gas fuel), with the rated

capacity of 1600kW each. However during commissioning these will initially be powered by

diesel until fuel gas becomes available.

When operational, the facility will be self-sufficient, utilising 100% CSG to facilitate power

generation (of up to 50 megawatt – 28MW for Train 1 and 20MW for Train 2/3) for the plant

and associated infrastructure. Additionally, backup generators will be implemented within

the facility to cater for periods of minimum turndown or complete shutdown. Each of these

generators are equipped with low NOx emission systems.

2.1.9.4. Plant and Instrument Air (Unit 35) and Nitrogen (Unit 39) Two 50% motor-driven air compressors will supply utility air, instrument air, and feed air to

the Nitrogen Generation Package. The diesel star-up/back-up Air Compressor Packages will





supply all necessary air required for initial commissioning activities. N2 will be used as

“blanket” gas for selected storage tanks and as a purge gas during pre-commissioning and

commissioning stages. N2 gas will be supplied to the facility by nitrogen generation units. A

liquid nitrogen back-up system will also be provided.

2.1.9.5. Firewater Systems (Units 33) The QCLNG Facility will be equipped with a self-sufficient fire protection system, supplied by

the utility water system and stored in two (2) firewater tanks. This firewater system is

common for both Train 1 and Train 2 facilities, as well as the LNG Jetty. The use of passive

protection within the processing plant equipment and the reserved fire-water system will

minimise the release of liquid spillages to surface water or land. The fire protection and

safety systems include:

fire water – underground distribution loop and above-ground system;

fire and gas detection systems – response to release of combustible, hazardous and/or

low temperature gases and fires;

fire proofing – all major structural steel and insulated vessels in the liquefaction section

that normally contain flammable or combustible hydrocarbon;

fire water tank; and

fire water pumps – diesel driven.

2.1.9.6. Fuel Gas A fuel gas system will provide usable fuel gas (under high pressure and low pressure) and

will engage initial start-up (black start) to generator turbine drivers1, six (6) refrigerant

compressor turbine drivers2, fire heaters2, flares, as well as tank and vessel blanketing. Fuel

gas will be implemented during the commissioning process and will continue to be in use

throughout the lifetime of the facility. Once the hot oil system is started up, fuel gas supply is

changed from the black start fuel gas to the start-up fuel gas slipstream downstream of the

feed gas heater.

2.1.9.7. Hot Oil System (Unit 34) A closed loop, hot oil system will provide the process heating requirements for the facility.

Waste heat generated from the CH4 compressor gas turbine exhausts will be recovered via

1 Use of high pressure gas 2 Use of low pressure gas





the Waste Heat Recovery Units to circulate heat through the oil. Exhaust from the C3H8 and

C2H4 compressor gas turbine is not recovered. A gas fired hot oil heater will be implemented

to cover both LNG trains as a backup during minimum turndown periods but will also feature

during start-up.

2.1.9.8. Refrigerant Storage Refrigerant storage will be provided for both the C2H4 and C3H8 systems, allowing for

periodic replenishment of each refrigerant circuit, as well as storage during maintenance.

These systems will be common to both Train 1 and Train 2.

2.2. Associated Infrastructure

2.2.1. Water Supply, Management and Storage

2.2.1.1. Potable Water Potable water is currently supplied to the project (including the TCF) through the GAWB

pipeline. All potable water supplied to the site, including that supplied to the TCF and all

permanent and construction offices, is currently monitored in accordance to the AS/NZS

5667.1:1998 Water quality – Sampling (as per the Potable Water Monitoring Process

Procedure (25566-500-GPP-GHX-10014) for compliance with the Australian Drinking Water

Guidelines (ADWG) and the relevant Australian Standards. During construction, the primary

activities which demand the use of potable water are concrete batching and pipe hydrostatic

testing. During CSU and operational activities (up to TCCC), the main demand for potable

(or demineralised) water use is for amine makeup and pipe flushing as discussed below.

2.2.1.2. Water treatment system (Unit 36) The water treatment system has been designed to treat water from GAWB to generate

demineralised water, service water and fire water. The unit will utilise a sodium hypochlorite

injection package, an ultrafiltration package, brackish water reverse osmosis (BWRO)

package, and an electro-deionisation (EDI) package. It will produce the demineralised water

required for the amine storage tank, demineralised make-up and facility wash water.

2.2.1.3. Stormwater Management (non-process areas) Throughout construction, a stormwater drainage system has been used to direct all runoff to

either the diversion drains (east and west) or sediment basins. Full details of the site

management of surface water can be reviewed in the CECP, Attachment 8 – Stormwater

Quality Management Plan (25585-500-GOI-GHX-00089).





During CSU, any uncontaminated stormwater will be diverted to the sediment basins to

manage discharge to Port Curtis. Should the rainfall event exceed the respective basin

design capacity, the gravitational discharge of stormwater will be through the rock-lined

spillway to the marine environment.

The final design of the sediment basin is for the installation of low-flow pipes to ensure the

constant drainage of the basin. However, the current infrastructure allows for turbid

stormwater to be retained, treated and later mechanically discharged. Further information

regarding the management of storm water runoff during CSU and initial operational activities

(up to TCCC) is detailed in Section 5.3 of this document.

2.2.2. Waste water and effluent management The project will produce waste water and effluent during CSU. This will include sewage

effluent, waste process water (from Unit 36 discussed in section 2.2.1.2) and stormwater

from process areas (treated via Unit 29). Each source will be treated and disposed

separately. Sewage effluent will continue to be transferred from the sewage collection tanks

and transported to the sanitary lift station located in Area 11. Additionally, sewage produced

from operational buildings will flow underground to sumps before being pumped to the

sanitary lift station. The sewage will continue to be transported directly to the GAWB pipeline

located at the northern border of site. Stormwater from the process areas will be treated

through the onsite wastewater treatment system (Unit 29) and discharged through the

Seawater Outfall, located on the jetty. Waste process water effluent (from Unit 36) will also

be discharged to the Seawater Outfall. The clean condensate generated from the Inlet air

chilling (IAC) unit which is released to the atmosphere from the gas turbine inlet coils will be

routed to the stormwater system. Further information regarding the onsite waste water and

effluent management has been detailed in Section 5.3.2 of this document.

2.2.3. Amine and Hot Oil Drainage Areas that may contain amine (e.g. amine process area, wastewater tank, or wet flare

knock-out drum pumps) are bunded for containment, draining to dedicated underground

collection headers and ultimately the amine sump drum. This amine will be collected and

can be recycled back in to the process. In the event of an incident during CSU, the

immediate removal of material from these containment areas will be through the use of

wastewater trucks, which can either remove the waste off-site for disposal / treatment, or

transferred to the wastewater tank.





The hot oil system does not discharge to the wastewater sump. If equipment containing hot

oil requires draining, it will either be returned to the hot oil storage tank via pipe (using

nitrogen) or a temporary storage tank.

2.3. Other CSU activity

In addition to the process based commissioning activities and associated environmental

releases, there will be other activity that has the potential to impact the environment if

appropriate mitigation and management is not implemented. This includes materials storage

and handling, waste management and dangerous goods/hazardous substances. Details of

these are presented below with corresponding management and monitoring (where

required).

2.3.1. Lube oil flushing Lube oil system flushing will be performed by circulating mineral or synthetic oil through each

piece of equipment, using external filters, heaters, pumps and moisture removal equipment.

The purpose of the oil flushing is to remove all impurities from the oil circuits and prevent

impurities from entering critical devices, such as machine bearings, during normal operation.

2.3.2. Chemical cleaning Some pipework and equipment will require chemically cleaning which involves the circulation

of chemicals (diluted in a solution). The transportation, storage, usage and removal of the

chemicals will be undertaken in line with the site’s management of dangerous goods and

hazardous substances as outlined in Section 5.4. The chemical effluent created from the

process will either be discharged as trade waste (subject to approval) or regulated waste.

2.3.3. Degreasing of the Acid Gas Removal Unit Degreasing of the Acid Gas Removal Unit will be done by circulating clean demineralised

water at ambient temperature throughout the liquid system to remove the bulk of dirt, loose

scale, slag and debris. The system will then be flushed with a three (3) percent Potash

Solution. This procedure is necessary to remove oil, grease, remaining debris and scale

from piping and equipment. Removal of these contaminants greatly reduces possibilities of

equipment fouling and amine solution foaming. After flushing with Potash solution, the

system will be rinsed with demineralised water.

2.3.4. Materials Storage and Handling All materials required for the commissioning phase of the LNG facility will be stored, handled

and disposed of in accordance with relevant legislation, Australian Standards (AS) and the

project’s EA. Refer to CECP Attachment 17 – Waste Management Plan (25566-100-G01-





GHX-00059) and Attachment 24 – Dangerous Goods and Hazardous Substances

Management Plan (25566-100-G01-GHX-00066).

2.3.5. Waste Management Efficient use of available resources and effective waste management are an integral

component of the commissioning phase. This includes minimising the potential effects of

odour, short-term pollution and any long-term contamination of soils, air or water.

The identification, handling, segregation and disposal of waste generated from

commissioning activities shall be consistent, and in accordance, with the CECP Attachment

17 - Waste Management Plan (25566-100-G01-GHX-00059). This procedure considers best

practice environmental management (BPEM) and includes the state legislative requirements

of Environmental Protection (Waste Management) Policy (EPP Waste) 2000 and the

Environmental Protection (Waste Management) Regulation 2000. For the CSU activities,

the generation of any additional waste streams (classified as trackable (regulated) and

general wastes) will be controlled in line with this CEMP, permit conditions and the above

legislative requirements.

Possible trackable waste during CSU activities can include waste oil-based paints,

adhesives, spent solvents, waste lubricating oils, spent oils, oily sludge or sewage sludge.

These hazardous wastes are required to be removed from site for approved treatment

and/or disposal. An indicative list of waste generated specifically from CSU activities is

presented in Table 1.

Table 1: Waste generated during CSU phase – indicative list

Waste

General /Non CSU specific waste

General waste

Cardboard

Timber

Process related (CSU up to TCCC)

Spent solvents

Potash wash effluent

Spent amine from AGRU

Chemical cleaning solution from the Hot Oil System/Regen Heater Coils/Heater

Waste drums and containers

Cartridge filters – Cleaning pigs from the LNG piping cleaning.





Waste

Utility related (CSU up to TCCC)

Inorganic sludge from demineralisation unit

Oily sludge from CPI oil separator

Maintenance related

Spent lubricating oil

Used batteries

Oily filters / rags

Grease

2.3.6. Dangerous Goods and Hazardous Substance Handling The construction of the LNG facility to date has required the storage and use of various

dangerous goods and hazardous substances (DG&HS). The current environmental

management of DG&HS is being performed under CECP Attachment 24 – Dangerous

Goods and Hazardous Substances Management Plan (25566-100-G01-GHX-00066).

During CSU and initial operational activities (up to TCCC), there will be a requirement to

obtain and use other DG&HS as prescribed in Table 2. This table presents an indicative list

of expected catalysts and chemicals required during CSU.

Table 2: Hazardous substances utilised during CSU phase - indicative list

Hazardous Substance

Maintenance related products

Grease

Lube oil

Synthetic Oil

Process related chemicals

100 wt% Diglycolamine

Ethylene Refrigerant

Propane Refrigerant

37% Hydrochloric acid solution

50% Sodium hydroxide

Antifoam agent

Citric Acid Powder

Hot Oil

Pot ash

Mineral Oil





Hazardous Substance

Na-dodecylbenzene sulphonate powder

Na-EDA Powder

Soda ash

Sodium bisulphate

Sodium hydrosulphite powder

Sodium hydroxide (50% liquid)

Sodium hyperchlorite (10%)

Sodium tripolyphosphate (100%)

Sulphuric acid

Utility related chemicals

Diesel

Unleaded Fuel

Hydraulic oil

2.4. Construction Phase Activities during Commissioning

The QCLNG project requires the construction, commissioning and operation of 2 LNG trains

which will mean there is simultaneous operation (SimOp) within/nearby the same area. A

SimOps Risk Screening Workshop was held on-site between QGC and Bechtel on 12–13th

December 2012, with the key objective of identifying high-level risks caused by:

1. CSU activities occurring simultaneously with construction activities; or

2. Operational activities by QGC while construction or commissioning activities are

underway by Bechtel.

Once the risks were identified, mitigation measures were identified to reduce the risks to an

acceptable or as low as reasonably practicable (ALARP) level.

With relevance to Bechtel’s CSU activities and this CEMP, one key environmental SimOps is

the construction of Train 2 during the commissioning or operations of Train 1. Throughout

the CSU phase, construction activities will continue to be performed within Train 2 and

surrounding areas. All construction activities will continue to be undertaken in accordance

with the CECP, Australian legislation, standards and guidelines. As an example, airborne

dust particles will continue to be suppressed through routine operation of water carts

(utilising a polymer dust-suppressant solution). This service will concentrate on the

trafficable areas surrounding the CSU and process areas, in order to reduce the potential of





delays or interruptions. Further information regarding construction processes is detailed in

the Construction Execution Plan (25585-500-GOI-GCX-00001).





3. Overall Environmental Management Approach

Without considering best practice environmental practices and preventative control

measures, CSU activities have the potential to impact the local environment and surrounding

sensitive receptors. There is therefore a requirement to provide a consistent management

approach towards reducing and/or eliminating these impacts during the commissioning of

the project. This section of the CEMP outlines the overarching environmental management

strategy for CSU on the project. Specific management and monitoring measures are

discussed in Section 5.

3.1. Performance Criteria

The performance criteria for the commissioning phase are:

Compliance with applicable environmental approvals, licenses, permits, and legislation;

General consistency with the commitments from the Environmental Impact Statement

(EIS) and Supplementary Environmental Impact Statement (sEIS);

Adherence to non-legislative requirements and commitments; and

Response to changes in environmental conditions during the proposed works through

review, monitoring and control programmes.

3.2. Environmental Policies

3.2.1. QGC Environmental Policy QGC has adopted environmental principles as part of their Health, Safety, Security and

Environment Policy (HSSE Policy). The objectives listed in the policy have been

incorporated into the QCLNG project’s objectives and performance criteria to verify that the

Company’s corporate objectives are met on site. The QGC HSSE policy is attached in

Appendix B.

3.2.2. Bechtel Environmental Policy The project is committed to achieving a ‘Zero’ environmental incidents performance by

planning the prudent use of resources and technology while complying with contractual,

statutory, regulatory and industry requirements, as defined in Bechtel’s Core Process 401:

Environmental Policy. The HSSE Execution Plan (25566-100-G01-GHX-00001) further

outlines this commitment. The Bechtel Environmental Policy is attached at Appendix B.





4. Environmental conditions and values

Due to the nature and location of the project, there are a variety of environmental conditions

and values that are relevant to the commissioning phase of the QCLNG project. Project

relevant environmental aspects have been detailed in the CECP and the associated aspect

specific procedures. There is also a general description of the environmental values in the

EIS and sEIS. This section presents a summary of the environmental values and

commitments identified for the CSU phase of the QCLNG facility.

4.1. Climatic Conditions

The Gladstone region has a sub-tropic climate; averaging 267 days of sunshine annually, an

average temperature range of 27.2°C (maximum) and 12.7°C (minimum) and a mean rainfall

of approximately 750mm. The heaviest rainfall generally occurs during summer (December

to February) in line with the northern tropical monsoonal season. With strong influences

from sea breezes, the region experiences diurnal seasons, with variation in air temperature

greatest in winter (June to August).

The site operates a weather station to monitor the localised weather. This information will be

available for use in the context of how it may influence potential air quality (and noise)

impacts from CSU. In relation to dispersion meteorology, the project EIS identified:

The site is dominated by moderate wind speeds (65% of wind at 2-5 m/s), which

provides for relatively good dispersion conditions for stack sources;

The prevailing wind direction are easterlies and south-easterlies; and

Drainage flows are westerlies.

4.2. Sensitive receptors (noise, vibration and air quality)

The LNG Facility is situated approximately 4km from the nearest single residence on islands

in Port Curtis, 7.5km from major residential areas in Gladstone City and 9km from the

community at South End on Curtis Island. As discussed in section 2, the TCF is also located

within the project site and is, as such, a sensitive receptor from a noise and air quality

perspective.

The nearest industries to the proposed LNG Facility are Cement Australia and Queensland

Energy Resources, on either side of Landing Road at Fisherman’s Landing (adjacent to the

wharf facilities). Other industries within the local area include Rio Tinto Aluminum (7km to





the south-west), Orica (7.3km to the south-southwest) and the NRG Gladstone Power

Station (9.3km to the south-southeast). Environmental values to be protected from changes

in noise, vibration and air quality include:

The health and biodiversity of ecosystems;

Human health and wellbeing within a suitable acoustic environment; and

The amenity of the community.

In relation to marine noise, the environmental objective is to ensure that no significant

behavioral disturbance occurs which may impact the long-term survival chances of the

individual or species. Appendix 5.14 of the EIS surveyed typical noise emissions from

construction activities against these receptors, with the results of computer modeling

(presented as noise contour maps) shown in Figure 3. The red contours represent noise

levels between 54 and 45 dBA (approximately). Orange contours represent noise levels from

42 to 39 dBA (approximately). Yellow contours represent noise levels between 36 and 33

dBA and green between 30 and 15 dBA. This gives an indication of the potential extent of

noise at the prescribed levels.

Figure 3: Noise emissions from construction activities under typical weather





No on-site quantitative noise monitoring has been requested by the regulatory agencies (as

a result of a compliant) to date and dust has been monitored in the qualitative fashion over

the duration of construction. The management of noise and air quality for CSU is discussed

in section 5.

4.3. Visual (Lighting)

A landscape and visual impact assessment was undertaken as part of the project EIS. The

predominant sensitive visual receptor is the Great Barrier Reef World Heritage Area

(GBRWHA) and The Narrows (listed on the Australian Heritage Commission Register of

National Estate). The EIS denotes that ‘there will be no additional visual impact during Stage

5 (Commissioning of the LNG Facility) beyond that assessed in the previous stages’ i.e.

construction. The site is also visible from a number of publicly accessible viewpoints as

detailed in the EIS. Lighting is discussed in more detail in section 5.

4.4. Ecology

The site is located in relatively close proximity to sensitive terrestrial and aquatic ecological

receptors. This includes un-vegetated mud and sand banks, mangroves, saltmarsh and

seagrass meadows. These vegetated areas contribute to the complexity and biodiversity of

an estuarine environment for various marine flora and fauna communities, including benthic

invertebrates.

These habitats also provide a feeding habitat for waders listed as migratory under the EPBC

Act and protected under international migratory bird agreements (i.e. JAMBA and/or CAMBA

and/or ROKAMBA.) (Note: The intertidal area adjacent to the plant has been established as

not being significant for roosting or foraging. There are more suitable sites on Curtis Island).

Figure 4 shows the location of the salt pans (yellow) and the mangroves (green).





Figure 4: Location of saltpans and mangrove areas in conjunction with facilities

Other ecological values in the area include but are not limited to:

The GBRWHA extends seaward from the low water mark on the Queensland coast,

covering the waters and islands within the Port of Gladstone including Curtis Island.

This area is also classed as a Matter of National Environmental Significance under

the commonwealth Environmental Protection & Biodiversity Conservation (EPBC) Act

1999, and is listed on the register of National Heritage Places.

The southern boundary of the Queensland State Great Barrier Reef Coast Marine

Park (GBRCMP) crosses The Narrows between Friend Point on the mainland and

Laird Point on Curtis Island.

The Curtis Island National Park, which extends north of Graham Creek, on the east

side of Curtis Island.

The Curtis Island State Forest, which is located approximately 10km north-west of

the facility on the northern side of Graham Creek.

These values along with those noted below are important in the context of CSU given the

interface with the marine environment (i.e. the LNG Jetty seawater outfall). Details of how





water and wastewater will be managed on site are presented in section 5. Further details of

the ecological value of the surrounding area are contained within the EIS and sEIS.

4.5. Groundwater

The QCLNG EIS identified two groundwater bores on Curtis Island. Aquifer details provided

from the Groundwater Database maintained by the DERM (now DEHP), indicated relatively

poor groundwater quality. Initial site monitoring indicated groundwater depths of 2.3m to

2.5m, and that these levels are expected to change to an elevation of 1.0/2.0 AHD, with the

rise primarily following extended wet weather periods.

Since undertaking bulk earthworks, groundwater monitoring bores (currently eight) were

installed in the Holecene sediments of the site’s coastal perimeter and have been monitored

monthly for groundwater levels and groundwater quality (pH, Electrical Conductivity

Titratiable Acidity, Chloride, Sulphate, and filtered Iron and Aluminum). When compared to

historical baseline data, this monitoring has shown that test results have remained within

acceptable project limits and that groundwater levels have risen as expected.

4.6. Surface Water

As discussed in section 2.2.1.3, the natural surface water drainage on site has been

reconfigured in to a stormwater drainage system which features a number of internal drains,

sediment basins (referenced as 1 to 7) and two clean water diversion drains (east and west).

This stormwater system drains to the marine environment through designated discharge

points. Surface water quality monitoring has been undertaken on site throughout

construction.

4.7. Marine water

In addition to the publicly available information, the project has been collecting background

seawater quality data since December 2012 from the Construction Dock (CD) (close to the

LNG Jetty intake/diffuser area) and the Material Offloading Facility (MOF). Details of the

results are documented within the QCLNG Uptake and Discharge of LNG Tank Hydrotest

Water process procedure (25585-500-GPP-GHX-10037). The in-situ and laboratory results

have also been compared to relevant guidelines i.e. Guidelines for Fresh and Marine Water

Quality, Australia and New Zealand Environment Conservation Council (ANZECC). This

information will be useful in understanding and managing any potential impacts that CSU

activities may have on the marine environment.





5. CSU activities, potential environmental impacts and

associated management

This section presents the activity specific potential environmental impacts associated with

the CSU of the QCLNG plant. The Process Environmental Flow Diagram for emissions

(Figure 5) and for wastewater/effluent (Figure 6) highlights the plant processes with their

associated outputs. The section is broken in to individual aspects (air, noise, water etc)

noting the relevant CSU activities and the potential environmental impacts (air emissions,

solid waste, and water / effluent streams). Relevant activities are then discussed in detail

along with specific management strategies.

An internal risk assessment (including a workshop) was undertaken, which was documented

in an environmental risk register. The risk process was undertaken in accordance with

Bechtel processes and generally followed the following key steps:

Identification of the potential CSU sources or activities which may influence the impact to

atmospheric, marine or socio-economic aspects of the project, and where possible,

quantification of the risk.

Assess the effectiveness of the as-built engineering controls, and operational procedural

controls for the identified activity, to generate an associated environmental residual risk

level.

Review the residual risk which accounts for any prescribed mitigation/management

strategy and prioritise items for further control in order to reduce the risk to ALARP.

The information from the risk assessment was used to inform the potential environmental

impacts and management stipulated in this document.













5.1. Air Quality Management

There will be various air emissions released as part of CSU activities (Table 3) and these

will differ from the releases during plant operation. The equipment source of air emissions

will include:

Wet/dry and marine flares;

Gas turbine generators;

Compressor gas turbines (Methane, Ethylene, Propane);

Hot oil heater and Regeneration gas heaters;

AGRU; and

Nitrogen Rejection Unit

There will also be emissions associated with the fire water pumps, back-up power

generators, the emergency air compressor and the standby generator at marine terminal

building.

Table 3: Potential air quality impacts during CSU activity

CSU – General Activity Details (where required) Potential environmental impact

Point source emissions

Flaring emissions

through wet/dry and

marine flares

Increased flaring is a normal and

expected part of the commissioning

and start-up of the plant. It could also

result from a trip of the plant or cool

down of the plant or out of

specification ship.

Point source release of NOx, trace

hydrocarbons and carbon monoxide to

atmosphere

Localised release of heat from flare

CSU of gas turbine

generators

The plant features 3 GTG’s, located in

area 10

Point source release of NOx to atmosphere

CSU of compressor gas

turbines

Train 1 and Train 2 feature 2 propane

compressor gas turbines, 2 ethylene

compressor gas turbines and 2

methane compressor gas turbines

Point source release of NOx to atmosphere

CSU of hot oil heater Intermittent operations only

NOx CO and VOC

CSU of regeneration gas

heaters

Intermittent operations only NOx CO and VOC






Point source emissions

CSU of AGRU Intermittent operations only CO2, trace H2S (SO2) and minor CH4

CSU of Nitrogen Rejection Unit

- NOx

Fugitive emissions

Release of fugitive

emissions from process

Fugitive emissions are releases of

feed gas or its component gases that

are not released via a stack, duct or

vent.

Greenhouse gas emissions

Release of volatile organic hydrocarbons

5.1.1. Performance criteria The key performance criteria for air quality management during CSU is noted in the

Environmental Authority, Schedule B, Table 1 – Contaminant Release Points (see Table 4

below) and Schedule B, Table 2 Contaminant Release Limits to Air (see Table 5 below) .

Condition B8 highlights the monitoring requirements of any releases.

Table 4: Relevant condition information from the EA – Contaminant release points

Emission Source

Train 1 Emission Sources Train 1 Compressor Gas Turbines (* 6)

Acid Gas Removal Unit 1

Nitrogen Rejection Unit 1

Other LNG Facility Emissions Sources Gas Turbine Power Generators ( *3)

Marine Flare

Process Flares (Wet and Dry Gas)

Regeneration Gas Heaters 1 & 2

Hot Oil Heaters 1 & 2

Fire Water Pumps (diesel * 3)

Back-Up Power Generators (diesel * 6)

Emergency Air Compressor (diesel * 2)

Standby Generator at Marine Terminal Building (diesel * 1)





Table Note: The EA also presents details of the emission sources for Train 2 and 3. However, these

are not relevant at this stage of CSU. Reference can be made to the EA as required.

Table 5: Relevant condition information from the EA – Contaminant release limits to air

Emission

Sources

Equipment

Number

(Release Points)

Contami

-nant

Release

Release

Height

Above

Grade

Emission

Velocity

(m/sec)

Maximum

Release Limit

Monitoring

Frequency

Train 1 Gas Compressor Turbines

Propane

Compressors

1TC-1411 (RP1)

1TC-1421 (RP2)

NOx

34 25 61 mg/Nm3

(dry) @ 15%

O2 & 3.4

grams/second

All stacks during

commissioning

of the facility and

one stack per

year thereafter

on rotational

basis

Ethylene

Compressors

1TC-1511 (RP3)

1TC-1521 (RP4)

NOx

34 25

Methane

Compressors

(with Waste

Heat

Recovery)

1TC-1611 (RP5)

1TC-1621 (RP6)

NOx

49.2 22

Power Generation Turbines

Gas Turbine

Power

Generators

1TG-3101 (RP13)

1TG-3102 (RP15)

1TG-3103 (RP15)

NOx

25 25 61 mg/Nm3

(dry) @ 15%

O2 & 3.4

grams/second

All stacks during

commissioning

of the facility and

one stack per

year thereafter

on rotational

basis

Table Notes:

1) See Figure 5 for location of emission sources / release points.

2) The EA notes that the above NOx release limits are applicable during all timings except start-

up, shut-down and calibration of emission monitoring devices. The start-up duration is allowed

up to 30 minutes.

3) The EA references a fourth Gas Turbine Power Generator which would not be constructed

until Train 3. This has therefore not been presented within this management plan





5.1.2. Point Source Air Emissions

5.1.2.1. CSU Flaring Increased flaring will occur in association with the CSU of the gas-fed processes, particularly

during periods of purging and cooling down. Commissioning source emission rates and

frequencies are likely to be intermittent and are a normal and expected part of CSU. Table 6

summarises the objective, performance criteria, management strategy, monitoring

requirements, reporting, responsibilities and corrective action process for flaring.

Table 6: Air quality management – CSU flaring

Element Air quality management – flaring

Objective To understand that flaring is a necessary part of the CSU and operational process but

ensure that it does not present an unacceptable risk to the environment.

Performance criteria Compliance with relevant legislation and permits i.e. the Environmental Authority which

has the following conditions associated with flaring:

B11 - The flare must be equipped with a flare tip design to provide good mixing with air, flame stability and achieve a minimum Volatile Organic Compound (VOC) removal efficiency of 98% under varied gas flow rate and meteorological conditions and meet the best practice design standards [e.g. NSW EPA: Protection of the Environmental Operations (Clean Air) Amendment (Industrial and Commercial Activities) Regulation 2005, or the US EPA Code of Federal Regulations: 40 CFR 60.18 and 40 CFR 63.11)]

B12 - The flare must be equipped with a continuously burning pilot or other automatic ignition system that assures gas ignition and provides immediate notification to appropriate personnel when the ignition system ceases to function.

B13 - The flare must be designed to handle large fluctuations in both the volume and the chemical content of gases

B14 -Visible smoke and particulate emissions must not be permitted for more than five minutes in any two hour period during normal operating conditions, other than during LNG train start-up.

B15 - Contingency plans and emergency procedures must be developed and implemented for non-routine situations to deal with foreseeable risks and hazards including corrective responses to prevent and mitigate environmental harm (including a contingency plan when plant shuts down for maintenance or other reasons).

Management

strategy

A range of design, management and mitigation measures have been incorporated into the facility to address potential air quality issues. These have been based on a range of technologies for key emissions sources as part of the internal QGC Best Available Techniques (BAT) assessment.

Dry & Wet Gas Flares during non-operational conditions

These flares feature pilot burners so to ensure immediate ignition during the gas release.





Element Air quality management – flaring

A smokeless flare is being installed which will result in near zero particulate emissions.

The flaring system shall be commissioned early in the program, and be functionally available (e.g. flare pilots being operational) during the commissioning of the plant with CSG.

The flare tip is fabricated so that it shall meet the required standards and specifications.

Marine flare

It is expected that the marine flare will only be used in the event of a system failure

or if capacity if exceeded.

Staged cool down

There is an automatic blow down sequence that applies to staged cool down of the

plant. This is documented in the ‘Sequential narrative for the automatic blowdown of

the plant’ (25566-100-3DR-V04F-33002). This will assist in minimising the amount

of flaring required.

Monitoring and

auditing

Note: The EA references the flares as emission sources but no contaminant release

limits to air are prescribed. No monitoring is therefore proposed.

Monitor any complaints regarding odour and investigate.

Reporting No reporting requirements specific to flaring.

Responsibility EM will be responsible for ensuring all actions and objectives of this CEMP are

addressed and complied with.

Corrective action Corrective actions will be implemented as per Bechtel Core Process 413: Non-

conformance Corrective Actions.

5.1.2.2. CSU of gas turbines, hot oil heater and regeneration gas heater The start-up of different components within the gas turbines may create some potential

volatility in emitted flue gas as the system runs through a variety of mechanical performance

tests. Emissions to air from the gas turbines comprise primarily NOx, CO and CO2, small

quantities of PM10 and trace quantities of hydrocarbons. These non-normal conditions which

are outside general operating parameters will occur intermediately and for a short duration.





Table 7 summarises the objective, performance criteria, management strategy, monitoring

requirements, reporting, responsibilities and corrective action process relating to power

generation during CSU.

Table 7: Air quality management – power generation

Element Air quality management – CSU of GTG’s, compressor gas turbines, hot oil heater

and regeneration gas heater

Objective To ensure commissioning, start and running of the GTG’s and compressor gas turbines

do not present an unacceptable risk to the environment, and to minimise impacts where

possible.

Performance criteria Compliance with the Environmental Authority – Oxides of nitrogen limit for GTG’s and

compressor gas turbines (refer to Table 4 and Table 5 above)

Management

strategy

Selection of equipment, design and configuration

Equipment was identified and reviewed against Best Available Techniques (BAT) which will assist in the control of NOX and CO2 emissions.

A range of turbine configurations were assessed for 1, 2 and 3 train operation which has assisted with optimising power generation.

A variety of refrigeration compressor drivers were considered for the project, with Nuovo Pignone aero-derivative LM2500+G4s with Dry Low Emissions (DLE) selected in a 2x2x2 configuration for each LNG process train. Design NOx emissions from this configuration of LM2500+G4s + DLE are as low as or lower than any of the other options considered in detail (although electric motor drives were rejected during the concept assessment and not considered in detail due being unproven technology for use in this environment). Thermal efficiency was as great as or greater than any other option considered, with greater thermal efficiency indicating lower rates of greenhouse gas emissions arising from operation of the compression drivers. For NO2, the refrigeration drivers reduce thermally generated NOX emissions without any dry emission controls (e.g. water injection) through a lean, louvered combustion liner and by utilizing premix technology (fuel: air equivalence ratio and flame temperature which reduces hot spots and thermal NOx

generation).

For CO2 (and the subsequence influence on NOx emissions), its minimisation during CSU activities will be largely dependent on the yield from testing of the system’s thermal capacity, fuel consumption, and power generation.

Inlet air chilling (IAC) on the main refrigeration turbines optimises the efficiency of the turbines over a range of ambient temperatures and humidity improving annual LNG production. The use of IAC can provide additional power per Train to the liquefaction Refrigeration Compressors on a warm day for an investment of less power to the IAC utility plant. IAC also provides an operational benefit for upstream operations, as it can provide a stable feed demand throughout daily temperature swings, thus improving the efficiency of upstream operation.

Waste heat recovery units will be installed on turbine exhausts prior to start-up.





Element Air quality management – CSU of GTG’s, compressor gas turbines, hot oil heater

and regeneration gas heater

These will reduce the requirement for use of fuel gas burners associated with the dehydration and mercury components of the LNG process (CO2 reduction).

Testing and tuning

Each of the units will be separately tested as they are handed over from construction. This will limit the cumulative air quality impact from CSU.

The GTG’s and compressor gas turbines will be tuned and tested to ensure they are operating within equipment specifications

Where possible, the fuel type used during CSU will be maintained in order to minimise variability of the system.

Hot Oil Heaters

The Hot Oil Heater will be commissioned using gas-firing as oppose to the operational supply from the WHR system. There should therefore be less volatile and the heaters should perform in accordance with manufacturer specifications.

The CSU of the heaters will be confined to a specific area of the plant which alleviates the need for the system to provide external pre-heating services which are typically required under operational conditions. This allows for this system to be relinquished from the stress of normal operations (generally 40% of loading).

Monitoring and

auditing

Undertake emission air quality monitoring (NOx) for the GTGs and the compressor gas

turbines in line with requirements of EA (refer to Table 4 and Table 5 above). This will

initially be undertaken by Bechtel but a third party will be engaged at a later stage in

CSU.

Ongoing local weather monitoring.

Monitor any complaints regarding odour and investigate.

Auditing of compliance will be undertaken on a regular basis.

Reporting EM will be responsible for ensuring that all non-conformances are reported to QGC who

will in turn notify the respective regulatory authority if required.









5.1.2.3. AGRU The system is designed to remove carbon dioxide (CO2) from the feed gas using a

conventional Acid Gas Removal Unit using Diglycolamine (DGA). Acid gases (CO2 and H2S)

and H2O vapour contaminates are stripped from the feed gas and vented to the atmosphere

for conversion to SO2. There will also be some minor CH4 emissions.


requirements, reporting, responsibilities and corrective action process relating to the AGRU.

Table 8: Air quality management – AGRU

Element Air quality management – AGRU

Objective To ensure the AGRU does not present a risk to the environment.

Performance criteria Note – the Environmental Authority notes the AGRU as contaminant release point but

no release limits to air are nominated.

Management strategy No specific environmental management measures are prescribed for the AGRU.

Monitoring and

auditing

As noted above, the EA references the AGRU as an emissions source but no

contaminant release limit to air is prescribed. No monitoring is therefore proposed.

Reporting EM will be responsible for ensuring that all non-conformances are reported to QGC

who will in turn notify the respective regulatory authority if required.





5.1.3. Fugitive Emissions Fugitive emissions are releases of feed gas or its component gases that are not released via

a stack, duct or vent. These emissions are generally associated with equipment and plant

leakages or plant upset and/or failure. It is expected that there will be minimal release of

fugitive emissions associated with CSU as pneumatic, hydro and other forms of testing will

occur prior to introduction of feed gas. There will also be fugitive emissions associated with

the Nitrogen Rejection Unit as discussed below.


requirements, reporting, responsibilities and corrective action process for fugitive emissions.





Table 9: Air quality management – fugitive emissions

Element Air quality management – fugitive emissions

Objective To ensure fugitive emissions do not present an unacceptable risk to the construction

workers, commissioning workers, the community or other sensitive receptor.

Performance criteria Compliance with the Environmental Authority conditions and any relevant legislation,

including:

B16 - The holder of this environmental authority must ensure that all reasonable and practical measures are taken in the design and operation of the plant to minimise fugitive VOC emissions. Reasonable and practical measures include but are not limited to:

a) Implementation of a monitoring program to regularly leak test all units/components including pumps, piping and control, vessels and tanks; and

b) Operating, maintenance and management practices to be implemented to mitigate fugitive VOC sources (Note: not relevant to CSU)

B17 - The ducting and extraction systems that transfer effluent gases from one location to another must be constructed, operated and maintained so as to minimise any leakage of VOC’s and vapours to the atmosphere occurring from these sources.

B18 - In the event of emissions of contaminants occurring from industrial plant or ducting systems that transfer effluent gases from one location to another, the fault or omission that resulted in that emission must be corrected as soon as practicable.

Management

strategy

There will be various tasks undertaken prior to CSU (including pneumatic testing hydrostatics testing, leak testing and flange management) that will control the risk of fugitive emissions. This will be complimented by quality control activities which would be expected to identify potential deficiencies that may influence fugitive emissions.

All piping shall be supported, guided or anchored so as to prevent excessive vibration, deflections or stress to equipment.

General environmental management including routine work area inspections.

Monitoring and

auditing

No specific environmental monitoring of fugitive emissions is to be undertaken. However,

engineering, quality and environmental inspections will identify any potential issues.

Reporting No specific reporting requirements for fugitive emissions.









5.2. Noise

During the CSU phase, there will be instances of intermittent and variable noise events

which will occur over several months. The main source of noise will be flaring although there

will be some additional noise generated as a result of pipe blowing, venting during purging,

and depressurising after tightness testing, seen in Table 10. Appendix 5.14 of the EIS

presented primary predictions of noise and vibration from the construction and operational

activities; however no correlation with CSU activities was identified.

Table 10: Potential noise impacts during CSU activity


Flaring emissions

through wet/dry and

marine flares

(Area 8)

See Table 3 for details of the likely

causes of increased flaring during

CSU.

Generation of noise creating potential

disturbance to social or ecological

receptors outlined in section 4.

Pipe blowing Involves testing at low pressure (i.e. 3

to 5 bar) with noise levels usually less

than hearing protection requirement

levels.

Generation of noise creating potential

disturbance.

Venting during purging

Use of nitrogen Generation of noise creating potential

disturbance.

Depressurising after

tightness test

Use of air Generation of noise creating potential

disturbance.

5.2.1. Performance criteria The key performance criteria for noise emissions during CSU are noted in the Environmental

Authority, Schedule D, Table 1 – Noise Component Limits for the LNG Plant. The relevant

monitoring of these noise limits will be conducted in accordance with required standards

when requested by the regulatory agencies.

5.2.2. Point Source Noise emissions

5.2.2.1. Flaring This flaring system will generate noise during CSU, with passing noise estimated to be

approximately 120dBA (LAeq). As discussed in section 2 and 5.1.2.1, flaring is required for the

emergency combustion of CSG or LNG fuel during CSU and whilst the objective is to

minimise the amount of flaring, its use is a component which is not routine or predictable.





Plausible mitigation techniques and management measures are therefore limited. Table 11

summarises the objective, performance criteria, management strategy, monitoring

requirements, reporting, responsibilities and corrective action process for flaring.

Table 11: Noise emission management - flaring

Element Noise management - flaring

Objective To ensure the flaring commissioning activities do not present an unacceptable nuisance

to any sensitive or commercial place and to minimise any potential noise impacts as a

result of CSU activities.

Performance criteria Compliance with the Environmental Authority conditions and any relevant legislation,

including:

D1 - Noise from the construction or operation of LNG plant activities must not cause environmental nuisance at any sensitive place or commercial place.

D2 - When requested by the administrating authority, noise monitoring must be

undertaken within a reasonable and practicable timeframe nominated by the

administrating authority to investigate any complaint (which is neither frivolous nor

vexatious nor based on mistaken belief in the opinion of the authorised officer) of

environmental nuisance at sensitive place or commercial place, and the results must be

notified within 14 days to the administrating authority following completion of monitoring.

Zero non-compliances with project specific noise criteria at noise sensitive receptors and

with the EPP (Noise)

Number of noise complaints from local community

Management

strategy

Any planned fuel release, and subsequent flaring, will be undertaken during daytime where possible. However, the lengthy time required to undertake and complete flaring may not be possible within dedicated times.

Flaring activities will be conducted in as short a time as possible but with appropriate consideration for safety.

Monitoring and

auditing

If requested by DEHP, monitoring will be conducted as per Schedule D, Table 1 – Noise

Component Limits for the LNG Plant of the EA, or as directed by the regulatory agency.

Any noise monitoring will occur at the source of the noise complaint, and will be

performed in accordance with the latest edition of DERM Noise Management Manual

and AS1055.







Element Noise management - flaring





5.2.2.2. Pipe air blowing Pipe air blowing is one of the techniques that may be utilised when ‘flushing’ the pipes. The

network of pipes will be evaluated and divided into segments which are manageable. This

along with the defined pressures will determine the number of compressors, where they are

located, and how they are operated. Table 12 summarises the objective, performance

criteria, management strategy, monitoring requirements, reporting, responsibilities and

corrective action process for pipe blowing.

Table 12: Noise emission management – pipe blowing

Element Noise management – pipe blowing

Objective To ensure the pipe blowing activities do not present an unacceptable risk (or nuisance)

to the facility workers, the community or the environment.

Performance criteria Adherence with the conditions of the EA i.e. noise limits

Zero non-compliances with project specific noise criteria at noise sensitive receptors and

with the EPP (Noise)

Number of noise complaints from local community

Management

strategy

Site personnel notification through the daily communication sheet when pipe blowing is to be undertaken.

Pipe blowing generally to be undertaken at site worker break times.

Monitoring and

auditing

If requested by DEHP, monitoring will be conducted as per Schedule D, Table 1 – Noise

Component Limits for the LNG Plant of the EA.





Corrective action Corrective actions will be implemented as per Bechtel Core Process.





5.3. Water and wastewater management

There are various water and effluent streams (Table 13) that will require management at the

CSU stage of the project. All streams will be collected and directed to one of the following

segregated systems. See Figure 6.

1. Wastewater collection system(Unit 29) for potentially contaminated stormwater;

2. Reject Lift Station Sump within Unit 36 for discharge from the water treatment facility;

3. Sewage effluent system;

4. Internal stormwater drainage system (Non-contaminated water); and

5. Waste water tank (for overflow water collected from the amine storage and AGRU area)

As noted above, the management of plant pipework and firewater hydrotesting/flushing is

covered under the QCLNG Hydrotest & Pipe Flushing Water - Plant process procedure

(25585-500-GPP-GHX-10039);

Table 13: Potential water quality impacts during CSU activity

Water / effluent type Details (where required) Potential environmental impact

Stormwater from process

area

Potentially contaminated stormwater

from the process, utility and lab area

will be treated via Unit 29 and

discharged to the sweater outfall.

Potential for pollution to receiving water

environment

Discharge from the water

treatment facility

Water will be discharge from Unit 36

direct to the seawater outfall.

Potential for pollution to receiving water

environment

Sewage effluent system Sewage will be collected via truck and

discharged to the GAWB pipeline.

Potential for sewage spill

Potential for soil and water contamination

Stormwater (non-

process areas)

Uncontaminated stormwater will be

discharged to the internal drainage

system which flows to sediment basin

4.

Any potential impacts managed in

accordance with the current construction

procedure i.e. CECP.

Inlet air chill condensate

The uncontaminated condensate from

the Inlet Air Chilling Units (located at

the inlet of the compressor gas turbines

for the refrigerant compressors) is

released to the stormwater system.

No potential impact





Amine storage and AGRU area (overflow only)

The amine storage area and AGRU are

connected via pipe to the waste water

tank in Area 8 (see Figure 6). Any

rainwater in this area drains to a

dedicated sump (as oppose to the

process area spill containment sump).

At a set level, this is pumped to waste

water tank where it will be removed as

regulated waste.

Potential for soil and water contamination

CSU Activity

Loading of LNG Carriers

at the Jetty

Contaminant (i.e. hydraulic oil) release to

Gladstone Harbour.

Potential for ecotoxicological impacts to

marine species, the mangroves and

foreshore habitats.

5.3.1. Performance criteria The key performance criteria for water management are noted in the Environmental

Authority, Schedule C. Details are noted in the table below.

Table 14: Condition C11 from the EA – Water quality characteristic limits

Outfall discharge criteria

Quality

Characteristics

Limit Limit type Monitoring Frequency Monitoring

Location

pH (units) 6.0 – 8.5 50th percentile calculated daily

Continuous real-time online analyser

SP6, SP7

Temperature (oC) N/A N/A Weekly

Total Residual Chlorine (mg/L)

0.5 50th percentile calculated daily

Continuous real-time online analyser

SP7

1.0 95th percentile calculated daily

DO (mg/L) 4.0 Minimum Monthly

(in situ)

SP7

Total Residual Hydrocarbons (mg/L)

C10 – C36

10 Maximum Monthly (grab sample) SP6

Table Note: See Figure 6 for monitoring location points.





5.3.2. Stormwater from process areas and discharge from the water treatment facility


requirements, reporting, responsibilities and corrective action process for managing

wastewater.

Table 15: Water quality management – stormwater from process areas

Element Water quality management – stormwater from process areas

Objective To ensure the collection and treatment of stormwater from process areas does not

present a risk to the facility workers, the community or the environment.

Performance criteria Compliance with applicable EA conditions - Release to waters - Permitted contaminant

release and discharge point(s)

C1 - The holder of the environmental authority must ensure that the management of surface water and wastewater streams to be discharged to Port Curtis is conducted and implemented in accordance with a relevant Water Management Plan for each phase of the project

C2 - In the event of any inconsistency between the conditions of this authority and any Water Management Plan, the conditions of this environmental authority prevail.

C3 - The only contaminant(s) permitted to be released directly or indirectly to any waters from the petroleum activities authorised on the petroleum facilities license are the following releases to Port Curtis:

a) stormwater from the LNG Facility site and inlet air chill condensate via the stormwater discharge points to Port Curtis, prescribed in the relevant water management plan required by Condition (C1)

b) reverse osmosis concentrate, ultrafiltration reject and associated backwash/flush, process area stormwater and treated oily water via the LNG Jetty outfall as prescribed in the LNG Operations Water Management Plan

c) used seawater from hydrostatic testing of the LNG Tanks via three temporary outlets on the Construction Dock as prescribed in the QCLNG Project Process Procedure Uptake and Discharge of LNG Tank Hydrotest Water (As noted, this activity is cover under a separate Bechtel procedure)

C4 - The release of contaminants from the LNG Jetty outfall and from the stormwater discharge points prescribed in the relevant water management plan for the phase of the project:

a) must not produce any visible discolouration of receiving waters; nor

b) must not produce any slick or other visible or odorous evidence of oil, grease or petrochemicals nor contain visible floating oil, grease, scum, litter or other objectionable matter

Monitoring volumes and quality characteristics of release to waters






C5 - The total quality of reverse osmosis concentrate (ROC) released to waters on any

one day must not exceed 0.302 megalitres during operation

C6 - The daily volume and daily average flow rate in m3/s of the ROC component of the waste waters discharged to marine waters must be determined or estimated by an appropriate method with an accuracy of +/- 5%, and records kept of such determinations

C7 – Monitoring of the ROC component of the waste waters discharged to marine waters for pH, chlorine, dissolved oxygen, concentration and percent saturation, temperature, turbidity, and conductivity must involve instrumentation that is continuous, on-line, real-time and be able to be recorded and alarmed

C8 – Where monitoring of the hydrostatic test water in accordance with the QCLNG Project Process Procedure Uptake and Discharge of LNG Tank Hydrotest Water indicates that contaminants are required to be added prior to release of the water back to Port Curtis, the administrating authority must be notified and provided with the analytical results for the water prior to and post being treated.

C9 – Monitoring of contaminants released to Port Curtis from the waste streams prescribed Condition C3 (b) must be undertaken for the quality characteristics and parameters, at the monitoring point(s) prescribed in the LNG Operations Water Management Plan, and the frequencies specified in Schedule C, Table 1 – Quality Characteristics Limits

C10 – Any exceedences of limits in Schedule C, Table 1 – Quality Characteristic Limits are to be notified to the administering authority within 5 business days of receipt of analytical results.

C11 – From the commencement of discharge of contaminants to waters as permitted by Condition C3(b) and C3(c) water quality characteristics must be monitored in the receiving environment at locations and at a frequency identified by a suitably qualified person.

Stormwater Management

C12 – The holder of this authority must ensure that the management of stormwater is conducted and implemented in accordance with a relevant water management plan for the phase of the project. The Stormwater Management Plan must address at least the following:

a) the location of discharge points;

b) prevention of incident storm water and storm water run-off from contacting wastes or contaminants, or appropriate treatment of stormwater from process areas;

c) diversion of upstream run-off away from areas where it may be contaminated by bulk products being loaded or unloaded, wastes, contaminants or other materials; and

d) collection, treatment and disposal of all contaminated storm water run-off

Management

strategy

The ISBL design features 150mm concrete-lined containment ditches to delineate potentially contaminated stormwater from clean surface stormwater.






The wastewater collection system will collect potentially contaminated stormwater from equipment sumps, drains from rotating machinery, washdown water, level gauges, separators, filters, fuel gas knockouts, firewater, pumps, and from all parts of the plant, including inlet separator, process area (including refrigerant compressors), utility area (including GTG baseplates), and laboratory.

The water will be routed to Process Area Spill Containment Sump and then pumped through aboveground pipes to the Corrugated Plate Interceptor (CPI Oil/Water separator) using a floating oil skimmer.

The CPI unit will remove free oil and suspended solids from influent process wastewater. Treated water from the CPI unit will then be passed through the dissolved air flotation (DAF Effluent and Filter Package) unit to remove emulsified oil and then routed to a filtration unit for tertiary treatment and polishing. After treatment, the water will go to a holding tank before pumping to the LNG Jetty seawater outflow along with the reject water from the desalination plant.

Oily sludge from the CPI will be pumped to the sludge tank and periodically taken off-site for disposal/treatment. Oil from the CPI and float from the DAF will be pumped to a Waste Oil tank where it will be stored for final off-site disposal/treatment.

The amine unit is a closed-loop system and will not discharge to wastewater treatment units. Any areas which have the potential to be contaminated by amine, including the amine process area, wastewater tank or wet flare knock-out drums, will be bunded to prevent potential contamination of surface water runoff and surrounding soils. Any collected water will be treated as contaminated and disposed of via the wastewater sump.

The LNG Jetty seawater outfall will be in operation for the discharge of treated water.

Ongoing environmental work area inspections including review of bunds

Monitoring and

auditing

Undertake water quality monitoring in line with the requirements of EA (refer to Table 14

above).











5.3.3. Sewage Effluent Table 16 summarises the objective, performance criteria, management strategy, monitoring

requirements, reporting, responsibilities and corrective action process for managing sewage

effluent.

Table 16: Water quality management - sewage effluent

Element Water quality management – sewage effluent

Objective To ensure sewage collection and transportation activities do not present a risk to the

facility workers, the community or the environment.

Performance criteria Compliance with relevant legislation in terms of handling and transportation of sewage

effluent

Zero observable or measureable impacts to receiving environment.

Management

strategy

Sanitary waste, or sewage, from various sources throughout the facility will be collected and transported by sucker trucks to the sanitary lift station. From the lift station, all sewage will be pumped to the GAWB pressurised sewer line for treatment.

Monitoring and

auditing

Routine inspection of sewage effluent infrastructure and facilities to ensure no potential

for environmental harm







5.3.4. Stormwater (non-process area) The QCLNG facility footprint has been designed for diversion of clean water from

undeveloped areas and to avoid contaminated surfaces within the facility’s operational

areas. Stormwater from external areas is intercepted near the site boundaries and conveyed

directly to the eastern or western diversion drains. An internal drainage system has also

been implemented to facilitate the collection and diversion of facility captured stormwater

into sedimentation basins.

All non-process area stormwater will be managed in line with this current construction

practice and the CECP, Attachment 8 – Stormwater Quality Management Plan (25585-500-

G01-GHX-00089) and the relevant conditions within the EA (C12 – C21). This includes the





appropriate application of erosion and sediment control techniques such as sediment

fencing, rock check dams, flocculation and dewatering as well as more permanent measures

such as batter protection, shotcreting drains and applying compacted surfaces with 2.1 base

material.

For the LNG Jetty, the solid deck and roadway areas shall be sloped to prevent ponding,

and will generally run to the structures’ edge. A curbed area shall be provided on the loading

platform to contain hydraulic fluid spills.

5.3.5. Groundwater It is not proposed to utilise the groundwater as a source of supply for the LNG facility during

construction, start-up or operational phases. Therefore, the LNG facility is not expected to

have an impact on groundwater quality or quantity under normal circumstances.

Accidental spills or leaks have the potential to seep to groundwater. Appropriate control

strategies will be implemented through day-to-day operations to minimise the potential for

these as discussed in section 5.4.2. The management of groundwater will be maintained in

accordance the CECP, Attachment 7 – Groundwater Quality Management Plan (25585-500-

GOI-GHX-00049) and relevant conditions within the EA.

5.3.6. Loading of LNG carriers at jetty LNG is loaded through a 30” loading line maintained full of liquid and at the same

temperature as the tank liquid. The LNG is transferred to ships via three 16” diameter

loading arms. Another 16” diameter vapour return loading arm is provided to handle ship

storage displaced vapour, flashed vapour from the LNG product, and vapour generated from

the heat gain during ship loading.

This vapor is returned to the LNG storage tanks via a vapor return line. The loading arms are

of swivel joint design and are equipped with connections for continuous nitrogen purging.

Quick connect and disconnect couplers are also provided. Each loading arm is also

equipped with a remote operated valve, vent valve, and high pressure alarm.


requirements, reporting, responsibilities and corrective action process for managing the

quality of the marine water with respect to the loading of the LNG carrier at the jetty.





Table 17: Water quality management – Loading of LNG carriers at LNG jetty

Element Water quality management – loading of LNG carriers

Objective To ensure the LNG loading process is managed in a way that controls the risk to the

marine environment.

Performance criteria Compliance with applicable EA conditions

Zero observable or measureable impacts to receiving environment.

Management

strategy

Regular checks of the loading lines for leaks, excessive ice formation and movement

Testing of the Shutdown loading system before ship loading begins

Testing of the emergency disconnection release system every 6 months

Inspection and maintenance of hydraulic hoses

Permanent concrete bunding around loading arms

Permanent concrete bunding around standby diesel generator

Monitoring and

auditing

Routine inspection of hydraulic hoses etc







5.4. Dangerous Goods and Hazardous Substances

The key performance criteria for dangerous goods and hazardous substances (DG&HS)

management during CSU is noted in the Environmental Authority, Schedule G. The effective

management of DG&HS will be undertaken in accordance with the information presented in

this section of the plan and the CECP, Attachment 24 – Dangerous Goods and Hazardous

Substances Management Plan (25585-500-GOI-GHX-00066). Additional DG&HS will be

required during CSU (as listed in Table 2) which will present potential environmental risks

that will need to be appropriately managed. The CSU activities which have the potential to

have an impact on the environment from a DG&HS perspective are listed in Table 18.





Table 18: Potential impacts from DG&HS during CSU activity


Arrival and storage of chemicals for CSU

See Table 2 for list of chemicals Potential contamination to ground and water if not appropriately managed.

Storage and handling of DG& HS

See Table 2 for list of chemicals Potential contamination to ground and water if not appropriately managed.

Filling of permanent plant tank with hazardous substance

See Table 2 for list of chemicals Potential for spill, contamination of soil, atmosphere or water

Filling and flushing of facility equipment with lubricants

See Table 2 for list of chemicals Potential for spill, contamination of soil, atmosphere or water

5.4.1. Hazardous Substances Management and Storage The following table summarises the objective, performance criteria, management strategy,

monitoring requirements, reporting, responsibilities and corrective action process for

managing DG&HS during CSU.

Table 19: DG&HS management

Element DG&HS – management, handling and storage

Objective To ensure the handling, storage and use of DG&HS do not present a risk to the

environment.

Performance criteria Compliance with relevant legislation and approvals including Schedule G of the EA

Adherence to the CECP, Attachment 24 – DG&HS Management Plan and the objectives

defined in AS 1940:2004 and AS 3780:1994.

Zero environmental from the processing, handling or storage of DG&HS

Management

strategy

Storage, transportation, handling and disposal of all DG&HS including fuels, oils and chemicals will be undertaken in accordance with AS procedures to reduce potential leakage or spills.

Job Hazard Analysis (JHAs) will be utilised where applicable to identify potential DG&HS hazards and ensure they are reduced to ALARP

Loading and unloading of DG&HS will only be conducted by properly trained personnel

Robust spill response plans and procedures will be developed and implemented

DG&HS will be bunded to be in accordance with AS 1940:2004; AS 3780:1994; and AS 3833:2007.

Dedicated DG&HS storage areas will be used for DG&HS including the ISO






container area in area 12.

Containment structures (permanent or temporary) used around process storage tanks to retain spilled liquids, shall provide sufficient volumetric capacity to contain 110% of the largest tank in the enclosed area, with other contained equipment and tankage in place. Walls of the structures shall be of an impermeable material (temporary) or concrete (permanent), and be liquid tight and designed to contain a full static head of fluid. The inside area will ideally be sloped to a low point sump to allow for removal of accumulated liquid or spill by valved drain or vacuum truck. The structure will have at least one side adjacent to an access road.

Molecular Sieve Packing and Solvent Loading

Adequate space shall be provided for handling and storage of molecular sieves and solvents including mobile equipment access where appropriate. Platforms shall be designed to handle loads from hoppers where specified by manufacturer operations and maintenance specifications.

LNG

LNG spill provisions are included for the LNG tank roofs and the LNG loading platform on the jetty. The pump platform on the LNG tank roof has a spill pan and down-comer trough to collect spills from the LNG loading pump discharge systems and direct them away from the tank. The LNG loading platform has a spill curb around the loading arms and inlet piping with an outlet line to discharge directly to a separate containment sump, equipped with temperature detectors to alert to the presence of spilled LNG. Each loading arm is equipped with a hydraulic quick connect / disconnect system, and includes an emergency release coupling.

Temporary secondary containment will be used when hazardous materials are going to be transferred to smaller containers or the likelihood for a release exists.

An adequate number of spill kits will be provided around the site as determined by the EM based on current scope and risk of spills – see Spill Management below.

AGRU pot ash wash

The pot ash wash is a one off pre-wash that has to occur before the amine is introduced. Any temporary pipework that is required as part of the process will be bunded to control the risk of any spills.

Temporary tank will be used for mixing, storing and disposing all effluent.

Inline strainers/filters will be installed as required.

Temporary piping will tie in to the permanent system to allow for circulation.

Monitoring and

auditing

Weekly area inspections

Quarterly DG&HS environmental audits












5.4.2. Spill Management The prevention of spills, to both land and water, will be a primary objective throughout the

CSU phase. Spill prevention philosophies will be thoroughly communicated to site personnel

and will be strictly enforced. Bechtel will respond to and clean-up spills generated by Bechtel

craft personnel. Subcontractors will respond to and clean-up spills that they cause or are

responsible for in accordance with the CECP, Attachment 17 – Waste Management Plan

(25585-500-GOI-GHX-00059) and Bechtel will confirm the clean-up was satisfactory. All

personnel are required to immediately report spills to the Bechtel HSSE department,

regardless of the quantity spilled. Bechtel shall immediately notify QGC of any significant

spills (i.e. greater than 20L spilled onto land or any volume spilled into water). Other spills

will be documented and reported to QGC as soon as practicable.

5.4.2.1. Spill Response Each spill incident involves a unique environment and a unique set of circumstances.

Therefore, individual plans of action are developed and implemented as the EM or designee

evaluates the actual spill amount, hazards present, and surrounding environmental

conditions. Any spillage of wastes, contaminants or other materials must be cleaned up as

quickly as practicable. Such spillages must be cleaned up using dry methods that minimise

the release of wastes, contaminants or materials to any stormwater drainage system or

receiving waters.

Details regarding the Project Emergency Response Plan (ERP) and emergency response

actions for fires, explosions, spills, and other emergency situations onsite are found in the

HSSE Emergency Response and Preparedness Plan for Safety Incidents and CECP

Attachment 23 – Emergency Response for Environmental Incidents Management Plan

(25566-100-G01-GHX-00065). These plans address the emergency communication system

(e.g., two-way radios), off-site communication links (e.g. mobile phone), and spill

control/decontamination. These plans also establish the procedures and responsibilities in





the event of an incident requiring emergency response. In addition, CECP Attachment 16 -

Phase III Marine Fuel and Oil Spill Prevention and Response Management Plan (25566-100-

G01-GHX-00084) details specific emergency procedures to be implemented in the case of

environmental incidents such as spills and contamination to both marine and land

environments.

5.4.2.2. Spill Cleanup Actions Bechtel and its Subcontractors are responsible for cleaning up spills they are responsible for,

to Bechtel’s satisfaction. Bechtel is responsible for cleaning up spills that Bechtel Direct

Hire personnel cause. Spills (regardless of quantity) will be documented in the

Environmental Incident Register. Spills greater than 20L (i.e. “significant”) and/or any spills

in environmentally sensitive areas (e.g. the marine environment) will be documented on an

Environmental Incident Report.

Upon discovering a spill, non-essential personnel will be immediately removed from the

impacted area. The EM will be notified of the spill immediately. Personnel discovering the

spill shall eliminate sources of ignition (e.g. radios, cell phones, lighters) from the immediate

spill area. If it is safe to do so, the source of the leak will be stopped and the spilled material

should be contained within as small an area as possible by installing bunds or absorbents.

In the event of rainfall, personnel will place plastic sheeting or other protection over the spill

(if possible), to prevent mixing or washing by storm water.

Upon arrival at the scene, the EM will secure the area and establish a perimeter at a safe

distance from the spill. The EM will analyse the situation and determine if it is safe to clean

up the spill. The EM will coordinate and direct any emergency response effort for large and

serious incidents. If a Subcontractor is responsible, the Subcontractor may coordinate the

cleanup if approved by the EM and the CM. Appropriate personnel and response equipment

will be mobilised and the spill will be cleaned up under the guidance of the EM.

Contaminated cleanup waste will be properly contained and transported to the site WMA to

be disposed of as regulated waste. The EM or the CM shall notify the Senior Project

Manager and the onsite QGC representative immediately after any significant spill.





Table 20: Spill management

Element Spill management

Objective To ensure the commissioning activities do not present a risk to the facility workers, the

community or the environment.

Performance criteria Compliance with relevant legislation and approvals

Adherence to the CECP, Attachment 24 – DG&HS Management Plan and the objectives

defined in AS 1940:2004 and AS 3780:1994.

Zero environmental from the release of DG&HS

Management

strategy

The storage transportation, handling and disposal of all DG&HS including fuels, oils and chemicals will be in accordance with AS procedures to reduce potential leakage or spills

JHAs will be prepared (where applicable) to identify potential hazards and ensure they are reduced to ALARP

Spill response plans and procedures will be developed and implemented

Relevant site personnel will be trained in spill response

Monitoring and

auditing

Weekly area inspections







5.5. Waste Management

The key performance criteria for waste management during CSU are noted in the

Environmental Authority, Schedule E. The proactive management of wastes associated with

the CSU phase of the facility will be undertaken in accordance with CECP, Attachment 17 –

Waste Management Plan (25566-100-G01-GHX-00059 and in congruence with relevant

permits and legislation. CSU waste generating activities which have the potential to impact

the localised environment are listed in Table 1.





Bechtel is responsible for the overall management of waste for the QCLNG project until

TCCC to QGC. Until TCCC, Bechtel will continue to manage the handling and disposal of

wastes generated on site, under the arrangement implemented during the construction

phase of the project. Bechtel is committed to reducing waste production through the

implementation of the recovery, reuse and recycle philosophy, aiming to promote best

practice waste disposal methodologies. The following section details the collection,

handling, storage, transport, disposal and monitoring of site generated wastes throughout

the CSU phase.

5.5.1. Collection and Handling All wastes will be collected and segregated into their respective waste streams based on

their intended disposal option. Wastes will be stored on site and handled in accordance with

the Waste and Recycling Management Process Procedure (25585-500-GPP-GHX-10007)

and the EPP Waste. Bechtel has engaged a third party waste removal contractor

(Remondis) to facilitate the collection, transportation and disposal of all wastes generated

throughout the CSU phase of the QCLNG Project. This contractor is accredited for the

transportation and disposal of general and regulated wastes.

5.5.2. Storage and Handling All wastes will be stored and handled as detailed in the Waste and Recycling Management

Process Procedure (25585-500-GPP-GHX-10007). Waste storage areas will be clearly

marked and storage bins will be protected from environmental influences (e.g. wind, rain).

5.5.3. Transportation of Waste All wastes will be transported from Curtis Island to the mainland via barges used to deliver

materials and resources to the project site. Appropriate environmental mitigations will be

implemented to ensure minimal potential EH occurring. Those mitigation measures will be

assessed and documented through a job-specific Job Hazard Analysis assessment

conducted by the waste contractor.

5.5.4. Monitoring of Waste A project Waste Management Register (25566-100-ENV-REG-10005) has been established

for construction activities and will incorporate the recording and tracking of waste generated

from CSU activities. It covers differing types of waste streams (including trackable waste)

and includes the following details:

Type of waste

Volume





Origin

Dates of collection

Storage location

Any storage particulars

Date of disposal/recycling

Name and details of transporter and facility used to dispose the waste

Table 21: Potential environmental impacts from waste during CSU activity


Production of wastes

(Plant wide)

Generation of non-hazardous wastes (solid or liquid)

Potential for incorrect segregation

Inappropriate waste handling and disposal

Generation of hazardous wastes (solid or liquid)

Potential for incorrect segregation

Inappropriate waste handling and disposal

Potential for spills, contamination of soil, atmosphere or water

5.5.4.1. Waste Tracking Waste and Recycling Management Process Procedure (25585-500-GPP-GHX-10007)

details the waste tracking requirements for all waste identified as “Trackable Waste” under

Schedule 1 of the Environmental Protection (Waste Management) Regulation 2000. As

required under this regulation, a computerised recording and tracking system will continue to

be utilised during the CSU phase of the project, with the following information:

Name, address, local government area and contact details of generator;

Name, address, contact details and environmental authority number of receiver;

Name, address, contact details and environmental authority number of the licensed waste transporter;

The day and time the waste is given to the licensed waste transporter;

The load number;

Registration number of the vehicle transporting the load;

If the waste is a dangerous good:

The type and number of containers in which the waste is contained;

UN number;

Packing-group designator;

Dangerous goods class and any subsidiary risk;

The following details of the waste:

The type of waste;





Amount expressed in kilograms or litres;

Physical nature (solid, liquid, paste or gas);

Waste code; and

Waste origin code for the activity that generated the waste.

5.5.4.2. Waste Disposal Wastes which cannot be recycled or reused will be classified and segregated on site, then

disposed at an appropriately licensed waste facility.

5.5.5. Non-hazardous Wastes Non-hazardous wastes are classified as wastes that do not pose a threat to human health or

the environment. A number of non-hazardous wastes will be generated throughout the life of

the project. Effective waste management will include the segregation of various non-

hazardous wastes to facilitate implementation of the waste hierarchy principles.

5.5.6. Hazardous Waste Hazardous waste is characterised by its potential to cause harm to human health or the

environment if improperly handled and includes those wastes defined in the Waste

Reduction and Recycling Regulation 2011, Schedule 1 – Regulated Waste, as per Waste

and Recycling Management Process Procedure (25585-500-GPP-GHX-10007).

Regulated waste will be generated on-site as part of regular CSU and will be handled and

stored in accordance with legislative requirements. Regulated wastes will be transported off-

site by an appropriately licensed Subcontractor to an approved licensed disposal facility.

Table 22: Waste management

Element Waste management

Objective To ensure the commissioning activities do not present a risk to the facility workers, the

community or the environment by minimising the contamination of land, water and air.

Performance criteria Adherence with the objectives for Waste Management for criteria as defined in Waste

and Recycling Management Process Procedure and Environmental Protection (Waste

Management) Regulation 2000.

Minimise waste quantities being disposed as landfill and zero contaminant or waste

discharges to land or water

Management

strategy

Implementation of reduce, reuse, recycle philosophy

Appropriate on site waste segregation





Element Waste management

Appropriate storage and transport of all general and regulated waste

Educate and train all personnel regarding appropriate waste disposal requirements

Engagement of appropriately licensed waste service provider

Monitoring and

auditing

Weekly area inspections.







5.6. Lighting

The CSU activity which has the potential to have an impact from a visual perspective,

specifically in relation to changes in light, is flaring. Table 23 and Table 24 outline the

potential impact and management respectively.

Table 23: Potential impact from lighting during CSU activity


Flaring Night flaring through marine flare

Visual effects of flaring during night hours

Attraction/disruption to local marine wildlife and habitat

Table 24: Lighting management

Element Lighting

Objective To ensure the lighting impacts from CSU activities do not present an unacceptable risk

or nuisance to the facility workers, the community or the environment.

Performance criteria Adherence to the CECP, Attachment 4 – Lighting Management Plan (25566-100-G01-

GHX-00046).

Management

strategy

Lighting issues will be managed and maintained as per the construction phase of the project, in accordance with the CECP, Attachment 4 – Lighting Management Plan (25566-100-G01-GHX-00046).





Element Lighting

Monitoring and

auditing

Qualitative monitoring of lighting will be undertaken in line with the CECP.







5.7. Pests and Mosquito’s

The management of pest and mosquito will continue to be conducted in accordance with the

current construction practices and the CECP, Attachment 5 – Weed, Pests & Quarantine

Management Plan (25585-500-GOI-GHX-00047) and the CECP, Attachment 14 – Mosquito

& Biting Midge Management Plan (25585-500-GOI-GHX-00056).

5.8. Flora and Fauna Management

Flora and fauna will be managed under the DOR of QGC and maintained as per the

construction phase of the project, in accordance with the CECP, Attachment 12 – Terrestrial

Management Plan (25566-100-G01-GHX-00054) and the CECP, Attachment 13 – Marine

Ecology Management Plan (25566-100-G01-GHX-000055) and the EPBC Act.





6. General Environmental Management

6.1. Environmental Emergency Preparedness

Environmental emergency preparedness includes the development and implementation of

response procedures for possible emergencies, emergency response materials (e.g. spill

kits, firefighting tools), and the training of adequate numbers of onsite emergency

responders.

Bechtel’s Core Process 410: Emergency Environmental Preparedness and associated

HSSE policies and procedures describe the preparedness measures and response that will

be conducted in the event of an emergency. Environmental emergencies may involve spills

of dangerous goods on land or water, unanticipated discovery of hazardous materials,

wildfire, unauthorised discharge of storm water or other contaminated water, unauthorised

release of air pollutants, and unexpected encounters with wildlife. Response to an

emergency generally follows these steps:

Stop the source of the problem if it is safe to do so

Contain the problem to the extent possible

Report the problem

Clean up and remediate the affected resources.

6.2. Integrated Control and Safety System

In addition to unanticipated emergency response, the Integrated Control and Safety System

(ICSS) will assist with minimising incident releases or environmental incidents. The ICSS

primarily consists of the basic process control system; safety instrumented system (including

process shutdown and safety shutdown system); fire and gas systems; intelligent field

instrumentation and associated networks.

The degree of automation for each unit within the processing plant will allow for operators to

access all process information and controls through a distributed control system, allowing

the CSU team to maintain safe and reliable control of all plant equipment. The plant’s alarm

philosophy will assist with directing personnel’s attention to the system which requires

immediate attention to prevent hazardous situations from developing and/or minimise

harmful impact to the product, equipment or personnel.





The distributed control system shall be used for regulatory set-point control of the process

when within normal control range. It shall also be used for monitoring and alarming

individual measurements and other plant systems and equipment. For operational activities,

the safety instrumented system will have two separate components, one for LNG production

and one for ship loading. Each refrigeration compressor will have its own dedicated and

separate safety, fire and gas detection (and shutdown) system to protect the machines.

There will also be a number of on line analysers covering the initial feed gas, the process

area (moisture, H2S and CO2) and the LNG loading to the ships. As a last resort, the

emergency disposal of vapors and liquids may need to be executed through the following

techniques:

Table 25: Emergency disposal of vapours

Component Disposal

VOCs, organic air toxics (e.g.

process streams, fuel gas)

To wet flare / dry flare / marine flare

Acid gases To atmosphere unless the quantity of H2S in the stream precludes a safe

disposal

Air, N2 Atmosphere if contains no contaminants

LNG form tanks or relief valves Atmosphere

Liquid relief of organics and toxics Dependent on the material and CSU phasing:

Discharge to flare if liquid reliefs are flammable and combined with vapors.

Recycling of pure liquids (amines etc) within the process system.

Liquid accumulations in the flare drums that are unusable for recycling (due to contamination) must be removed via vacuum truck for later disposal at a facility able to accept such waste.





6.3. Environmental Incidents

An environmental incident will be regarded as any incident that has the potential to cause

harm to the environment. In the event that an environmental incident occurs, the following

steps will be followed immediately:

Prevent further pollution/environmental harm (including impacts on air, water quality, flora and fauna and noise environment);

Clean-up and/or control polluting substance(s);

Implement mitigation measures to prevent recurrence of a similar incident; and

Document the incident and instigate an incident investigation as appropriate.

Incidents will be reported within twenty-four (24) hours to the relevant Environmental

Manager. Incidents likely to cause off-site impacts or significant environmental harm will be

reported by QGC to relevant agencies as soon as practicable (within 24 hours) after

becoming aware of the incident, in accordance with statutory requirements. The notification

of emergencies or incidents will include the following:

The EA number and name of holder

The name and telephone number of the designated contact person

The location of the emergency or incident

The date and time of the release

The time the holder of the authority became aware of the emergency or incident

The estimated quantity and type of any substance involved in the incident

The actual or potential cause of the release

A description of the effects of the incident including the environmental harm caused, threatened, or suspected to be caused by the release

Any sampling conducted or proposed, relevant to the emergency or incident

Actions taken to prevent further release and mitigate any environmental harm caused by the release/mismanagement incident

Within fourteen (14) days following the initial notification of an emergency or incident or

receipt of monitoring results, further written advice must be provided, including:

Results and interpretation of any samples taken and analysed;

Outcomes of actions taken at the time to prevent or minimise environmental harm; and

Proposed actions to prevent a recurrence of the emergency or incident





6.4. Job Hazard Analysis

A Job Hazard Analysis (JHA) will be undertaken to help personnel identify, analyse and

manage the hazards associated with their work. The JHA will formalise the process of

hazard identification and management that most people follow when working. The JHA will

require personnel to examine the task they are about to undertake by:

Breaking the job into separate, defined steps.

Identifying the potential hazards (safety and environmental) that could occur during each defined step.

Listing the method to be followed to prevent or limit the risk of injury, loss, damage or environmental incident that may be caused by each potential hazard.

6.4.1. Site Environmental Plan Site Environmental Plans (SEPs) are area specific management plans with the intent of

identifying the inherent risk associated with the work activities required for the construction

and operation of the plant. Particular attention is given to environmental aspects of concern

previously identified within the project footprint; e.g. ASS, Erosion and Sediment Control and

Water Quality.

Guidelines for the creation and implementation of SEPs have been developed to ensure

consistency and continuity throughout all areas. Details regarding the creation procedure

and the content of an SEP can be found in the Guidelines for Developing SEPs process

procedure (25585-500-GPP-GHX-10025) and the Environmental Hazard and Risk

Management process procedure (25585-500-GPP-GHX-10016).

6.5. Structure and Responsibilities

Relevant to this process procedure, each person undertaking an activity on the QCLNG

project is responsible for conforming to applicable Australian and Queensland laws and

regulations. Furthermore, all personnel are responsible for the environmental performance of

the activity and for complying with the general environmental duty (GED) as set out in

Section 319 of the EP Act, which states:

“A person must not carry out any activity that causes, or is likely to cause,

environmental harm unless the person takes all reasonable and practicable

measures to minimise the harm.”

There is also a requirement to conducting the work in accordance with permit requirements

and Bechtel Core Process 405: Resources, Roles and Responsibilities.





6.5.1. Queensland Gas Company (QGC) As the owner and operator of the QCLNG project, QGC’s environmental responsibilities

include, but are not limited to:

Primary liaison with Australian Government authorities for the project;

Public and agency complaints;

When the administering authority advises QGC of a complaint alleging environmental nuisance, QGC must investigate the complaint and advise the administering authority in writing of the action undertaken or proposed;

When requested by the administering authority, QGC (or designated agent) must undertake monitoring (specified by the authority), within a reasonable and practicable timeframe (nominated by the authority), to investigate any complaint of EH at any sensitive or commercial place. The results of the investigation (including an analysis and interpretation of the monitoring results) and abatement measures implemented must be provided to the administering authority within fourteen (14) days of completion of the investigation, or receipt of monitoring results, whichever is the latter, and details of :

Proposed actions to prevent a recurrence of the emergency or incident

Outcomes of actions taken at the time to prevent or minimise EH/nuisance.

QGC to maintain a record of complaints and incidents causing EH, and actions taken in response to the complaint or incident, and retain the record of complaints required by this condition for five (5) years;

QGC must record the details, as identified in Section 9.2 of the CECP, for all complaints received and provide this information to the administering authority on request;

Submitting environmental permit applications and negotiating with relevant government agencies on permits and approvals as required;

Undertaking reporting requirements to the regulatory authority throughout the project; and

QGC will continue to work closely with indigenous communities so that cultural sensitivities relating to the project are duly considered and managed.

6.5.2. Bechtel As the Primary Contractor for the Engineering, Procurement, and Construction (EPC) scope

of work associated with the QCLNG facility, Bechtel is responsible for complying with its

obligations set forth in the Contract, permit requirements and management commitments.

Bechtel and its subcontractors are responsible for the implementation of this CEMP.

Described below are the specific responsibilities within the Bechtel project team for

maintaining environmental compliance during construction of the project.





6.5.2.1. Senior Project Manager The Senior Project Manager (SPM) is the Bechtel representative with overall management

responsibility for compliance with project’s environmental requirements related to Bechtel’s

scope of work. The SPM will be assisted as required by a Site Manager and HSSE non-

manual personnel.

6.5.2.2. Site Manager The Site Manager (SM) is the Bechtel representative responsible for overall construction

management of the site as well as the site compliance with all applicable environmental

requirements. The SM oversees implementation of the requirements set forth in this process

procedure, including:

Communication to project personnel regarding the environmental compliance requirements and other items of environmental importance;

Coordination with the Site HSSE Manager and the Environmental Services Manager to implement the overall environmental control programme;

Immediate contact with the Senior Project Manager if significant matters pertaining to environmental compliance arise, in support of Bechtel Legal Instruction 127;

Undertake monitoring where required under the Contract to comply with the conditions of approval; and

Communicate any work stoppages to the QGC site representative.

6.5.2.3. Health, Safety, Security and Environmental Manager Bechtel Health, Safety, Security & Environmental Manager (HSSE Manager) is responsible

for and/or will oversee the following activities:

Direct complaints to QGC Public Relations specialists as required; and

Review complaints and assess or direct response, corrective actions undertaken or other recommendations or modifications to practices and closed out.

6.5.2.4. Environmental Services Manager Prior to and during the undertaking of Commissioning, the Bechtel Environmental Services

Manager (EM) is responsible for and/or will oversee the following activities:

Implement and update this management plan in coordination with Bechtel’s construction team;

Review construction and commissioning work plans and activities to advise and determine that appropriate environmental controls are incorporated;

Coordinate environmental inspections and water quality monitoring to ensure commitments under this management plan are engaged;





Conduct environmental compliance evaluation of the analytical results relevant the water quality monitoring, and provide conditions of discharge (or contingency) based on the comparison to background and trigger values.

Auditing the system to confirm that activities are carried out is in line with the defined requirements and is producing the required outcomes.

Support the project team by providing guidance relating to environmental compliance issues and regulatory compliance support;

Coordinate with regulatory agencies after consultation with QGC;

Notify QGC and regulatory authority, if applicable, of environmental incidents and maintain a record of events relating to the incident and remedial action taken; and

Notify QGC of any activities or site changes that may require GCLNG to apply for new or amended environmental permits.

6.5.2.5. Environmental Inspectors Under the direction of the EM, the Environmental Inspectors (EIs) will directly support the

construction and commissioning team with all aspects of the commissioning phase,

including:

Raising awareness of potential environmental impacts with project personnel;

Directly notifying the EM and SM of any circumstances that warrant agency notification or management action in support of effective environmental compliance;

Monitor field commissioning activities which are planned and conducted in accordance with applicable environmental regulations and activity-specific requirements;

Participating in HSSE coordination meetings with project staff and QGC;

Participating in Commissioning coordination meetings;

When appropriate, participate in Government agency and authority meetings to review environmental requirements and compliance;

Conducting field inspection of commissioning activities for compliance with permit conditions and applicable environmental regulations;

Providing guidance to construction and commissioning teams for resolution of environmental compliance issues;

Conduct Environmental Training for personnel in relation to the undertaking of this activity, and provide guidance to facilitate compliance, communication and awareness.

Provide technical assistance and support to the Site Manager as required.





7. Programmes and Procedures

The implementation and application of various HSSE programmes, including recycling, water

monitoring, and safety improvements and self-audit programmes are consistent with the

QCLNG HSSE Management System (HSSEMS). Thorough procedures for which measures

of performance and compliance can be applied and audited are highlighted in the HSSEMS

in accordance with Bechtel’s Core Process 411: Monitoring and Measurement.

Detailed procedures will be developed and reviewed as required for commissioning and

operation throughout the project lifetime, in accordance to the CECP, the EA and the

HSSEMS Asset and Operational Integrity.

7.1. Awareness, Training and Competency

Project personnel will receive training specific to the undertaking of commissioning activity,

in order to familiarise them with the relevant management systems and requirements, as

appropriate to their roles and responsibilities. Attendance records for personnel

induction/training will be maintained by the project. The environmental management training

will address:

The role of this CEMP;

Personnel responsibilities;

Incident and emergency response;

Health and safety instruction;

Identification and understanding of the environmental issues outlined in this CEMP;

Specific topics as applicable to the individual’s role.

7.2. Communications

All communications will be conducted in accordance to the Bechtel Core Process 407:

Communication, with consideration of Exhibit D of the Prime contract.





8. Environmental Procedures and Forms

Environmental procedures and forms have been prepared for implementation during the

commissioning and operational activities to address risk and compliance management

systems. The management tools that are applicable include:

Procedures – provide instruction for specific environmental tasks for consistency in

approach and quality of results. Environmental procedures are developed for

managing issues including water monitoring and contamination testing, and are

linked to the Work Method Statements (WMS). A SEP will be developed, reviewed

and revised to display the required environmental mitigation measures adopted in

conjunction with the facilities environmental risk assessment.

Forms – including inspection reports, corrective action reports and audit reports.

8.1. Environmental Inspection

Environmental inspections will be performed and documented to verify that all environmental

requirements specified in this CEMP are being implemented and complied with during CSU

activities. The inspection schedule will be dictated by the type of activities occurring and the

environmental requirements relevant to those activities.

The environmental inspection checklists will include details of observations, the responsible

party, and when the situation will be mitigated. Example checklists are included within the

Environmental Monitoring Programme. The EM, or designee, will implement required

environmental improvements and maintain a database that will identify the status of

corrective actions. Open actions will be reviewed in the weekly progress meeting to help

promote timely closeout.

If necessary, “stop work” orders will be issued if activities are not in accordance with the

applicable environmental requirements, which may result in a significant adverse impact to

the environment if the activity continues. If such conditions exist, the EM, or designee, will

take appropriate action to halt and correct the problem and immediately notify the SM, and

other personnel, as appropriate. The construction activity in question will not resume until

corrective actions have been taken. Inspections records and audit reports will be available

for review by the relevant administering authority upon request.





8.2. Environmental Auditing

Auditing of the CEMP and CSU activities will be undertaken in accordance with the Internal

Auditing Process Procedure (25585-500-GPP-GHX-10027) and Bechtel Core Process 415:

Internal Audit for Environmental Management. This will be done to confirm that activities are

carried out in line with permit requirements, and are achieving the desired environmental

outcomes. These audits will be initiated by the Environmental Services Manager and

performed by an internal or external auditor. An audit protocol would include the following:

Review the scope, plan, and schedule of the audit;

Examine objective evidence to verify conformance with the CEMP and other associated

environmental management plan or procedural requirements;

Give specific attention to continual improvement actions developed in response to

previous audit findings;

Post-audit communication to present audit findings, clarify any misunderstandings and

summarise the audit findings;

Review audit programme annually and revise to reflect any improvements to the

methodology, auditors or timeframe of audits;

Complete an Audit Summary Report and have results discussed at the next

management meeting; and

List in the Audit Summary Report any continual improvement actions required to prevent

reoccurrence of any identified issues or to maximise opportunities for improvement.

8.3. Non-conformity, Investigation and Preventive Action

Through the use of inspections, internal auditing processes, complaints and incidents, actual

non-conformances and corrective actions will be identified. All non-conformances will be

recorded, assessed for significant risk and have corrective actions established as per

Bechtel Core Process 413: Non-conformance Corrective Actions. To ensure adequate

response, all non-conformances will be tracked through as preventative actions to minimise

the recurrence and to improve performance.

8.4. Document Control and Records

The system used for control of management and technical documents including “controlled”

documents subject to revision will enable the complete management of all documents,

including the identification of document or drawing lists, author and recipient management,





and various forms of reporting. All documents and records are controlled in accordance with

Bechtel Core Process 408: Documentation and Control of Documents.

8.5. Continual Improvement

To ensure the continued suitability and effectiveness of the CEMP and all other associated

management plans, a regular review and update of the environmental management

programme is to be undertaken, as per Bechtel Core Process 416: Management Review and

the Environmental Review and the QCLNG Continuous Improvement Process Procedure

(25585-500-GPP-GHX-10023).

8.6. Review

This CEMP, its functionality, implementation, and the associated elements of the

accompanying management systems, will be reviewed periodically for conformance with

project objectives, legal and other requirements. A review may also be undertaken following

request by the administering authority. The outcomes of the management review process

will be incorporated as improvements to this CEMP, associated management plans and

other plans and procedures, to facilitate regulatory and policy compliance and continuous

improvement.





APPENDIX A - Legislation, Industry Standards and Guidelines

Commonwealth Legislation

Environment Protection and Biodiversity Conservation Act 1999

National Greenhouse and Emissions Reporting Act 2007

Clean Air Act 2012

Queensland Legislation

Coastal Protection and Management Act 1995

Dangerous Goods Safety Management Act 2001

Dangerous Goods Safety Management Regulation 2001

Environmental Protection Act 1994

Environmental Protection Regulation 2008

Environmental Protection (Noise) Policy 2008

Environmental Protection (Air) Policy 2008

Environmental Protection (Water) Policy 2009

Environmental Protection (Waste Management) Regulation 2000

Petroleum and Gas (Production and Safety) Act 2004

Project-relevant approvals, processes & documentation

Environmental Authority (DEHP Permit Number: EPP00711513)

Prescribed Tidal Works OPW – LNG Jetty (GRC DA Number: 479/2011)

Prescribed Tidal Works OPW – Tidal Area Infrastructure (GRC DA Number:

239/2010)

Air

AS 3580 Methods for Sampling and Analysis of Ambient Air

AS 4323.1 – 1995 Stationary source emissions, Method 1: Selection of sampling

positions’

Queensland EPA Air Quality Sampling Manual, 1997, EPA

Soil and contamination

Best Practice Erosion and Sediment Control, 2008 IECA





“Draft Guidelines for the Assessment and Management of Contaminated Land in

Queensland, 1998, EPA

Dangerous Goods

AS 1940 Storage and Handling of Flammable and Combustible Liquids

AS 2809 Road Tank Vehicles for Dangerous Goods

AS 2931 Selection and Use of Emergency Procedure Guides for Transport of

Dangerous Goods.

AS 3780 The Storage and Handling of Corrosive Substances

AS 3833:2007 Storage and Handling of Mixed Classes of Dangerous Goods, in

Packages and Intermediate Bulk Containers

MARPOL Annexes I, II, IV and V

Standard for Marine Construction Activities within Gladstone Harbour (MSQ)

Noise

Queensland EPA Noise Management Manual (3rd Edition), 2000, EPA – check for

revision

Waste

Code of environmental compliance for certain aspects of regulated waste transport—

Version 2

Water

AS 2031 Selection of Containers and Preservation of Water Samples for Chemical

and Microbiological Analysis

ISO 5667-10:1992 Water Quality - Sampling - Part 10: Guidance on Sampling of

Waste Waters

Queensland Water Quality Guidelines, (Version 3) 2009, DERM





APPENDIX B - Environmental Policies

QGC HSSE Policy





Bechtel Environmental Policy