Wheatstone Emp Offshore Facilities Water Discharge MGMT Plan Stage 1

Wheatstone Project
Offshore Facilities and Produced Formation

Water Discharge Management Plan: Stage 1
Document No:
WS0-0000-HES-PLN-CVX-000-00101-000
Revision Date:
29 July 2014
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Chevron Australia Pty Ltd
Revision:
Wheatstone Project
Offshore Facilities and Produced Formation Water Discharge
Management Plan: Stage 1
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TABLE OF CONTENTS
ACRONYMS, ABBREVIATIONS AND TERMINOLOGY ....................................................... 3
1.0 BACKGROUND ............................................................................................................ 5
1.1 Project Overview .................................................................................................. 5
1.2 Proponent ............................................................................................................ 5
1.3 Environmental Approvals ..................................................................................... 7
1.4 Objectives ............................................................................................................ 7
1.5 Scope .................................................................................................................. 8
1.6 Public Availability ................................................................................................. 8
2.0 PROJECT DESCRIPTION ............................................................................................ 9
2.1 Overview .............................................................................................................. 9
2.2 Chemical Selection Process................................................................................. 9
2.3 Trunkline Flooding, Cleaning and Gauging ........................................................ 10
2.3.1
Flooding ............................................................................................... 10
2.3.2
Flooding Fluids ..................................................................................... 11
2.4 Trunkline Hydrotest ............................................................................................ 12
2.5 Trunkline Dewatering ......................................................................................... 13
3.0 EXISTING ENVIRONMENT ........................................................................................ 15
3.1 Oceanography and Water Quality ...................................................................... 15
3.2 Geomorphology & Benthic Habitats ................................................................... 17
3.3 Fish and Marine Fauna ...................................................................................... 17
4.0 ENVIRONMENTAL RISK ASSESSMENT .................................................................. 19
4.1 Risk Assessment Approach ............................................................................... 19
4.2 Discharge Characterisation ................................................................................ 20
4.2.1
Toxicity ................................................................................................. 20
4.2.2
Dispersion ............................................................................................ 21
4.3 Potential Impacts ............................................................................................... 23
4.3.1
Physical impacts................................................................................... 24
4.3.2
Toxicity Impacts.................................................................................... 24
4.4 Risk Assessment Summary ............................................................................... 24
5.0 ENVIRONMENTAL MANAGEMENT, MONITORING AND REPORTING ................... 26
5.1 Management Measures ..................................................................................... 26
5.2 Triggers and Corrective Actions ......................................................................... 26
5.3 Monitoring .......................................................................................................... 27
5.4 Hind-Cast Modelling ........................................................................................... 29
5.5 Reporting ........................................................................................................... 29
6.0 REFERENCES ........................................................................................................... 30

Printed Date: 11/8/2014
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TABLES
Table 1.1: Requirements of Commonwealth Ministerial Conditions: EPBC 2008/4469
relevant to this Plan ........................................................................................... 7
Table 2.1: Summary of Flooding Fluid Concentrations Pumped into the Trunkline ............... 11
Table 2.2: Summary of Flooding Fluids Discharged from Trunkline into Commonwealth
Waters following Hydrotesting Activities ........................................................... 13
Table 2.3: Summary of Flooding Fluid Discharge from Trunkline into Commonwealth
Waters during Dewatering ............................................................................... 13
Table 4.1: Species protection concentrations for Hydrosure 0-3670R based on the
NOEC* SSD from WET testing ........................................................................ 20
Table 4.2: Summary Risk Assessment outcomes for the dewatering of Trunkline
following FCG and Hydrotesting ...................................................................... 25
Table 5.1: FCGT and Trunkline Dewatering Management Actions or Standards .................. 26
Table 5.2: Monitoring Parameters and Criteria ..................................................................... 28
FIGURES
Figure 1.1: Planned Location of Project Infrastructure ............................................................ 6
Figure 2.1: Schematic of a Trunkline FCG PIG Train showing forewater and separate
slugs of flooding fluid ....................................................................................... 10
Figure 2.2: Typical Dewatering Pig Train .............................................................................. 14
Figure 3.1: Environment that may be affected (EMBA) from potential impacts associated
with FCG and hydrotest discharges ................................................................. 16
Figure 3.2: Classification of the Benthic Habitat within the Operational Area ........................ 18
Figure 4.1: Potential discharge impact envelopes based on a 48 hour median of
0.06 mg/L and typical discharge rate (0.5m/s pigging speed) .......................... 23
APPENDICES
APPENDIX A
CHEMICAL SELECTION PROCESS ................................................... 32
APPENDIX B
OVERVIEW OF THE ABU HAZARDOUS MATERIALS
APPROVAL PROCEDURE ........................................................................................ 41
APPENDIX C
MODELLING REPORT ........................................................................ 50
APPENDIX D
WHOLE OF EFFLUENT TOXICITY (WET) TESTING .......................... 64
APPENDIX E
EPBC
MATTERS
OF
NATIONAL
ENVIRONMENTAL
SIGNIFICANCE .......................................................................................................... 70

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ACRONYMS, ABBREVIATIONS AND TERMINOLOGY

C
Degrees Celsius
g/L
Micrograms per Litre
ACR
Acute to Chronic Ratio
ADBAC
Alky Dimethyl Benzyl Ammonium Chloride
ADCP
Acoustic Doppler Current Profiler
ANSIA
Ashburton North Strategic Industrial Area
ANZECC
Australian and New Zealand Environment and Conservation Council
ARMCANZ
Agriculture and Resource Management Council of Australia and New Zealand
BCF
Bioconcentration Factor
CAR
Compliance Assessment Report
CEFAS
Centre for Environment, Fisheries & Aquaculture Science
CFC
Chlorofluorocarbons
CHARM
Chemical Hazard and Risk Management
Cth
Commonwealth
DBNGP
Dampier-to-Bunbury Natural Gas Pipeline
DDG
DBP Development Group Pty Ltd
DG
Dangerous Goods
Domgas
Domestic gas
DOTE
Department of the Environment - formerly Department of Sustainability,

Environment, Water, Population and Communities (Cth)
Draft EIS/ERMP
The Environmental Impact Statement/Environmental Review and Management

Program
EC
Effect Concentration
EMBA
Environment that may be Affected
EP Act (WA)
Environmental Protection Act 1986
EPBC Act (Cth)
Environment Protection and Biodiversity Conservation Act 1999
EPBC 2008/4469
The Commonwealth Primary Environmental Approval and conditional

requirements for the Wheatstone Project. Commonwealth Government of
Australia, Minister for Sustainability, Environment, Water, Populations and
Communities, Hon. Tony Burke, 22 September 2011, with variations to EPBC
2008/4469 conditions 44, 45, 55, 56 and 66 made pursuant to section 143 of
the EPBC Act, as amended from time to time.
FCG
Flooding, Cleaning And Gauging
FCGT
Flooding, Cleaning, Gauging and Testing
HBFC
Hydrobromofluorocarbons
HCFC
Hydrochlorofluorocarbons
HES
Health, Environment and Safety
HFC
Hydrofluorocarbons

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HMAAF
Hazardous Material Approval Application Form
HMAP
Hazardous Materials Approval Procedure
hr(s)
Hour(s)
kg
Kilogram(s)
km
Kilometre(s)
LNG
Liquefied Natural Gas
LOEC
Lowest Observed Effect Concentration
Metre(s)
m/s
Metres per second
MDMP
Marine Discharge Management Program
mg/L
Milligrams per litre
MS 873
Ministerial Statement No. 873: The State (WA) Primary Environmental Approval,
and conditional requirements for the Wheatstone Project. Government of
Western Australia, Minister for the Environment; Water, Hon. Bill Marmion MLA,
30 August 2011 as amended by MS 903, MS 922, MS 931 and Attachments 1
to 4 and amended from time to time.
MSDS
Material Safety Data Sheet
MTPA
Million Tonnes Per Annum
Nearshore
Marine habitat from the 20 m contour to the shoreline
NOEC
No Observed Effect Concentration
ODS
Ozone-Depleting Substances
OFPFWDMP
Offshore Facilities and Produced Formation Water Discharge Management Plan
OPGGS(E)R
Offshore Petroleum Greenhouse Gas Storage (Environment) Regulations 2009
PCB
Polychlorinated biphenyls
(The) Plan
Offshore Facilities and Produced Formation Water Discharge Management

Plan: Stage 1
ppm
Parts per million
Project
Nearshore and offshore marine facilities, trunkline, and onshore facility
Practicable
Means reasonably practicable having regard to, among other things, local
conditions and circumstances (including costs) and to the current state of
technical knowledge (taken from the EP Act)
Proponent
SSD
Species Sensitivity Distribution
THPS
Tetrakishydroxymethyl phosphonium sulphate
UV
Ultra Violet
WA
Western Australia
WET
Whole of Effluent Toxicity
WP
Wheatstone Platform

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1.0
BACKGROUND
1.1
Project Overview
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Chevron Australia Pty Ltd (Chevron Australia) will construct and operate a multi-train
Liquefied Natural Gas (LNG) and domestic gas (Domgas) plant near Onslow on the Pilbara
Coast, Western Australia. The Wheatstone Project (the Project) will process gas from
various offshore fields in the West Carnarvon Basin. Ashburton North Strategic Industrial
Area (ANSIA) is the approved site for the LNG and Domgas plants.
The Project requires installation of gas gathering, export and processing facilities in
Commonwealth and State waters and on land. The initial Project will produce gas from
Production Licences WA-46-L, WA-47-L and WA-48-L, at the Wheatstone Platform (WP)
145 km offshore from the mainland, approximately 100 km north of Barrow Island and
225 km north of Onslow, and will also process gas from Production Licence WA-49-L
operated by Apache Corporation. Figure 1.1 shows the location of the Project.
The ANSIA site is located approximately 12 km south-west of Onslow along the Pilbara coast
within the Shire of Ashburton. The initial Project will consist of two LNG processing trains,
each with a capacity of approximately 5 million tonnes per annum (MTPA). Environmental
approval was granted for a 25 MTPA plant to allow for the expected further expansions. The
Domgas plant will be a separate but co-located facility and will form part of the Project. The
Domgas plant will tie-in to the existing Dampier-to-Bunbury Natural Gas Pipeline
infrastructure via third party DBP Development Group Pty Ltd Domgas pipeline.
1.2
Proponent
Chevron Australia is the proponent and the company taking the action for the Project on
behalf of its joint venture participants Apache Corporation, PE Wheatstone Pty Ltd a
company part-owned by Tokyo Electric Power Company, Kuwait Foreign Petroleum
Exploration Company and Kyushu Electric Power Company.

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Figure 1.1: Planned Location of Project Infrastructure

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Environmental Approvals
The Project was assessed through an Environmental Review and Management Program
pursuant to the Commonwealth Environment Protection and Biodiversity Conservation Act
1999 (EPBC Act). The Commonwealth Minister for Sustainability, Environment, Water,
Population and Communities approved the Project on 22 September 2011 by way of
EPBC 2008/4469, with subsequent variations to Conditions 44, 45, 55, 56 and 66 made
pursuant to Section 143 of the EPBC Act.
The Plan shall be read and interpreted as only requiring implementation of EPBC 2008/4469
for managing the impacts of discharges from Offshore Facilities on EPBC Act listed matters.
Amendments to the approvals in place for the Project may be made from time to time and if
so will be reflected in the next revision of this Plan. Table 1.1 lists the requirements of the
Commonwealth conditions relevant to this Plan.
The activities described in this Plan are also regulated via the Offshore Petroleum
Greenhouse Gas Storage (Environment) Regulations 2009 (OPGGS(E)R). The
OPGGS(E)R requires that an accepted Environment Plan (EP) be in place prior to the
commencement of a Petroleum activity. There are a number of accepted EPs in place (or
under assessment) which contemplate the Project. In addition to the controls described in
this Plan, a specific EP for Flooding, Cleaning, Gauging and Testing (FCGT), Dewatering
and Drying is under review with NOPSEMA (the regulatory authority for this activity).
Table 1.1: Requirements of Commonwealth Ministerial Conditions: EPBC 2008/4469
relevant to this Plan
No.
Condition
Section
45
The person taking the action must develop and submit the following plans
(and associated reports) to the Minister for approval, as component parts of
the Marine Discharge Management Program (MDMP).
The Plan
45 b.
Offshore Facilities and Produced Formation Water Discharge Management

Plan (OFPFWDMP) which must address discharges from offshore facilities.
The OFPFWDMP must include:
The Plan
Water quality targets based on the ANZECC Water Quality Guidelines

(2000)
Section 4.2
Trigger levels
Section 5.2
Management (actions)
Section 5.1
Corrective actions
Section 5.2
Monitoring programs.
Section 5.3
1.4
Objectives
The objective of this Plan is to meet the relevant requirements of Commonwealth EPBC
2008/4469 approval Condition 45(b) in that the Plan specifically addresses hydrostatic test
water discharges from offshore facilities and includes water quality targets based on the
ANZECC Water Quality Guidelines (2000); monitoring programs; trigger levels; management
and corrective actions.. The Plan also satisfies the requirements of Condition 46
(EPBC 2008/4469) in that it forms a stage of the MDMP.
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Scope
This Plan considers the Trunkline and Flowline discharges associated with precommissioning activities in Commonwealth waters including:
Flooding, Cleaning And Gauging (FCG)
Hydrotesting
Dewatering.
The discharges considered in this stage of the Plan will occur following the installation of the
carbon steel trunkline and flowlines (here in referred to as pipeline) for the transport of
treated gas from the WP. Subsequent plans will consider discharges from other activities
associated with the Project such as routine operational activities at the WP i.e. Produced
Formation Water and explain the management of these discharges.
1.6
Public Availability
The approved Plan will be made publicly available on Chevrons website within one month of
approval (EPBC2008/4469 Condition 8) unless otherwise agreed to in writing by the Minister
for Environment.

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PROJECT DESCRIPTION
The Project description which follows has been included for the purpose of contextualising
the management and monitoring measures which are required under this Plan. Elements of
the Project may be amended from time to time. The Project elements which are detailed in
this Plan should therefore be read as subject to any project amendments which are made
from time to time.
2.1
Overview
Following installation of the pipeline, pre-commissioning activities including FCGT are carried
out to prove the ability of the pipeline to contain product without leaking. Following FCGT the
pipeline is dewatered and dried. Dewatering activities are proposed to commence
approximately 12 to 36 months following FCGT of the Trunkline and approximately 12 to 24
months following FCGT of the Flowlines.
The timing is indicative, and subject to potential delays caused by weather events, vessel
availability and other unforeseen factors such as the readiness of both the offshore and
onshore operations scopes.
The planned FCGT activities and discharges occurring in Commonwealth waters that are the
subject of this Plan include the following:
Flooding, cleaning and gauging (FCG);
Hydrotesting; and
Dewatering.
The following sections describe the chemical selection process undertaken to select the
flooding fluid treatment as well as the FCG, hydrotesting and dewatering activities for the
Trunkline. The Wheatstone flowlines will also be subject to FCG but these activities will
require considerably smaller volumes of flooding fluids, which are dosed at or below the
chemical concentrations required for the trunkline FCG activities. Flowline discharges will be
in the range of the trunkline discharge plume (refer Section 4.2.2) and as such any impacts
associated with Flowline FCG, Hydrotesting and Dewatering will be encompassed by the
descriptions presented for the Trunkline in this Plan.
2.2
Chemical Selection Process
The chemicals considered for the treatment of the flooding-fluid were subject to a detailed
review and selection process as described in Appendix A. This involved four key analysis
steps:
1.
2.
3.
4.
Treatment Options Analysis.

Chemical Options Analysis.
Chemical Screening - using the Chevron Hazardous Materials Approval Process
(Appendix B).
Chemical Approval.
Treatment of flooding water with biocides and oxygen scavengers is a technical requirement
to prevent corrosion of the pipeline structures. In the case of the current project, the trunkline
will remain flooded for the longest duration, meaning that the selected treatment needs to
remain effective for at least 36 months.

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Following the application of the review and selection process (described in detail in Appendix
A) the following factors were also taken into account:
The volumes of flooding water required

The need for high effectiveness for an extended duration of flooding
Safety issues relating to handling and dosing of chemicals
Relative toxicity of available products.
On the basis of this analysis, Hydrosure 0-3670R was identified as the preferred option for
treatment of the flooding water and was subsequently approved for use by Chevron.
2.3
Trunkline Flooding, Cleaning and Gauging
The trunkline will be subject to FCG, commencing with the injection of a flooding fluid
(inhibited seawater) at the WP location from a vessel via a 6 down-hose (see Section 2.3.2
for a description of the flooding fluids) to verify trunkline integrity prior to introduction of
hydrocarbons,. A schematic of the process is provided at Figure 2.1.
2.3.1
Flooding
Up to 1000 m3 of flooding fluid (which is inhibited seawater and called forewater) will be
injected in front of a four pig train. The pig train consists of four pigs (devices that are
inserted into a pipeline for cleaning and inspection purposes) that travel through the trunkline
and clean and gauge the trunkline. The forewater is required to facilitate the launch of the
train at the WP location and control its progress through the trunkline. To maintain
separation of the pigs within the train, up to 500 m3 of flooding fluid will be injected between
each pig (separation slugs, requiring a total volume of 1500 m3 of flooding fluids). The
forewater and separation slug water is expected to have a residence time of less than two
weeks within the trunkline.
Figure 2.1: Schematic of a Trunkline FCG PIG Train showing forewater and separate
slugs of flooding fluid
To propel the pig train towards the shore the main flood will be injected behind the pig train.
As the main flood is injected into the trunkline it pushes the forewater and the pig train along
the trunkline. The stabilisation water (up to 7500 m3), forewater (up to 1000 m3) and
separation slugs (10001500 m3) will be discharged into an existing lined onshore storage
pond. If the main flood is insufficient to push the last of the pigs through then additional
flooding fluid (called overpump) will be injected at the WP site to move the last pig to the
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onshore location. The volume of overpump required will range from zero up to 10 000 m3
and is dependent on the receipt of the last pig of the four pig train.
The fluids associated with FCG are temporarily held in an onshore pond prior to hydrotesting
activities described in Section 2.4. A summary of the volumes of all fluids that are associated
with this activity are shown in Table 2.1.
2.3.2
Flooding Fluids
The flooding fluids injected into the trunkline for FCG and hydrotest activities will be
seawater, sourced from open water in the vicinity of the injection point at the WP location.
The seawater is chemically treated to prevent corrosion from oxidation and microbial action
for the duration the flooding fluid is expected to remain in the trunkline. The chemical
selection process for the treatment of the seawater to be flooded is detailed in Appendix A.
The same flooding fluid will be used throughout the trunkline with varying concentration
depending on the required residence time of flooding fluid.
To maintain the appropriate level of protection and provide flexibility in the project schedule
while reducing environmental impact when the flooding fluid is released, Hydrosure 0-3670R,
a proprietary chemical mixture designed for the treatment of water (neutralising bacteria and
dissolved oxygen) was selected for use in hydrotest water. Hydrosure 0-3670R contains
10-30% quaternary ammonium chloride as a biocide along with an oxygen scavenger and
corrosion inhibitor.
Hydrosure 0-3670R will be mixed with filtered seawater to achieve appropriate
concentrations to maintain trunkline integrity during FCGT activities prior to commissioning
(see Table 2.1). The dosage is dependent on the residence time of the flooding fluid in the
trunkline. A fluorescein dye is added to the main flooding fluid and overpump and hydrotest
fluid to visually identify leaks during hydrotesting. A calibrated chemical injection pump will
be used during trunkline flooding and the following parameters will be logged:
Time
Pressure
Flow rate and volume of water pumped
Volume of chemicals injected (concentrations).
Table 2.1: Summary of Flooding Fluid Concentrations Pumped into the Trunkline
Dosing
Sequence and
flooding fluid
Maximum
Hydrosure
Dye
Volume Concentration Concentration
(ppm*)
(ppm)
(m3)
Comment
Stabilisation
fluid
7500
385
Temporarily held in the onshore

pond
FCG
forewater
1000
385

pond
Water
between pigs
(separation
slugs) (total
volume)
1500
385
Overpump (if
required)
0 - 10 000
550
50


pond
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Dosing
Sequence and
flooding fluid
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Maximum
Hydrosure
Dye
Volume Concentration Concentration
(ppm*)
(ppm)
(m3)
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Comment
5a
Hydrotest
fluid
5b
Flooding fluid
in storage
pond, redosed before
reinjection
into the
trunkline
Main flood
(entire
trunkline
volume)
550
3500
Up to
20 000
Additional
dosing (assume
maximum
possible
concentration up
to ~1000 ppm)
220 000
550
50
Approximately 3500 m is taken

from the flooding fluid in the
onshore pond and used to
bring the pipeline up to
pressure. This volume will
either be discharged at the WP
during depressurisation or will
be sent back to the onshore
pond until ultimately discharged
3
as part of the full 20 000 m
retained onshore.
The flooding fluid held in the

pond (sequences 1,2,3 and 4)
is to be re-dosed with
Hydrosure 0-3670R prior to
reinjection into the trunkline,
and for eventual discharge as a
slug at the end of the
3
220 000 m flooding fluid
discharge
50
Discharged in Commonwealth
waters (WP site) ~45 m below
the surface, ~30 m above sea
bed
* ppm (parts per million)
2.4
Trunkline Hydrotest
The trunkline Hydrotest will be undertaken to establish the integrity of the trunkline following
FCG activities and will require the reinjection of approximately 3 500 m3 of the flooding fluid
contained within the temporary onshore storage ponds to bring the pressure within the
trunkline up to a minimum 175.6 bar. Following the hydrotest, up to 3 500 m3 flooding fluid
will be discharged back into the temporary onshore storage pond, or alternatively at the WP,
to return the trunkline to hydrostatic equilibrium. After the hydrotest all flooding fluids
remaining in the temporary onshore storage ponds (between ~16 500 m3 and 20 000 m3) will
be reinjected into the trunkline resulting in a simultaneous discharge of an equivalent volume
at the WP. The total volume discharged at the WP at the end of the hydrotest will be
approximately 20 000 m3.
The discharge(s) immediately following hydrotest will take place at the WP via a 6" outlet
positioned approximately two metres above the seafloor and aligned at 30 degrees to the
vertical. A summary of discharges during the hydrotest of the trunkline is provided below
(Table 2.2). These are the planned discharges into Commonwealth waters during the FCGT
activities.

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Table 2.2: Summary of Flooding Fluids Discharged from Trunkline into

Commonwealth Waters following Hydrotesting Activities
Flooding Fluid Description
Release of flooding fluids held in the trunkline

following reinjection of flooding fluids held in the
onshore lined pond (including maximum
overpump)
Discharge Location
WP location ~2 m above seabed, 50 m from the

outside edge of the rock blanket and water depth
of approximately 70 m
Discharge Port
6" outlet effectively positioned vertically upwards
Total Approximate Flooding Fluid

Discharge Volume following Hydrotesting
(m3)
20 000
2.5
(either discharged as one volume (20 000) or as

two volumes 3 500and 16 500)
Trunkline Dewatering
Following the completion of the hydrotest and subsequent discharges at the WP (refer
Section 2.4), the trunkline will remain flooded for a period between 18 and 36 months until
dewatering and drying. Dewatering will involve the discharge of approximately 220 000 m3 of
flooding fluid at the WP site. A summary of all discharges into Commonwealth waters has
been presented in Table 2.2. The volume in the trunkline shown in Table 2.3 includes a
contingency for an additional 10% on top of the trunkline flood volume.
Table 2.3: Summary of Flooding Fluid Discharge from Trunkline into Commonwealth
Waters during Dewatering
Trunkline
Onshore to WP
Discharge Location
WP location ~30 m above seabed
Discharge Port
13 outlet effectively positioned vertically

downwards
Trunkline Length (m)
221 000
Volume per meter of trunkline (m3)
0.896
Approximate Trunkline Flood Volume*

(m3)
200 000
Contingency Discharge Volume** (m3)
20 000
Total Approximate Flooding Fluid

Discharge Volume during Dewatering
(m3)***
220 000
* Volumes have been rounded to the nearest 10 000 m3

** 10% of the total Trunkline Flood Volume
*** Includes 20 000 m3 slug of flooding fluid re-dosed prior to injection
During dewatering, the flooding fluid will be discharged from a caisson attached to the WP.
The fluid will discharge through a 13 pipe oriented vertically downward at a depth of 45 m
below sea level (approximately 30 m above the sea floor). Based on design flow rates,
discharges associated with dewatering will occur over approximately six to eight days. The
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mixing and dispersion of the planned discharge was modelled and the results are described
in Appendix C. The chemical selection process, characteristics and toxicity evaluations of
Hydrosure 0-3670R are presented in Appendix A and Appendix D and discussed in Section
2.2, with potential impacts from the discharge discussed in Section 4.3.2.
The trunkline will be dewatered utilising a specifically designed pig train similar in make up to
a typical pig train shown in Figure 2.2. The pig train is designed to bulk dewater and remove
residual water to a level sufficient to commence drying operations. The internal surface of
the trunkline will be desalinated by pushing fresh air through the trunkline from onshore to
the WP.
Figure 2.2: Typical Dewatering Pig Train

It is important to note, that to account for potential degradation to the fluids held in the
temporary onshore storage pond for the trunkline hydrotest, , as described in Section 2.4,
and to ensure that flooding fluids reinjected during the hydrotest maintain the appropriate
level of trunkline protection during the wet storage period, the flooding fluids retained in the
temporary onshore storage pond will be re-dosed with an additional 550 ppm of Hydrosure
0-3670R (refer to Table 2.1) prior to reinjection. As a result, the onshore end of the trunkline
is conservatively expected to contain a slug of flooding fluid with an approximate volume of
20 000 m3 and a maximum expected concentration of approximately 935 ppm of Hydrosure
0-3670R (this concentration is considered a highly conservative estimate as it assumes zero
degradation during temporary onshore storage). The modelling of trunkline dewatering, as
described in Appendix C includes consideration of this slug of re-dosed flooding fluid.

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EXISTING ENVIRONMENT
This section describes the existing environment that may be affected (EMBA) by the
planned FCG and dewatering trunkline discharges. The EMBA (Figure 3.1) is considered
the maximum radius from the WP within which there is the potential for an environmental
affect to occur as a result of the discharge. An environmental affect is considered possible
where the median concentration of Hydrosure 0-3670R in the marine environment exceeds
a threshold criteria of 0.06 mg/L over a 48hr exposure duration, with the rationale for this
consideration provided in Section 4.0. The environmental receptors described in this section
are considered to potentially occur within the EMBA and are relevant as EPBC Act listed
matters.
3.1
Oceanography and Water Quality
The EMBA occurs in a transitional climatic region between the dry tropics to the south and
the humid tropics to the north. The surface waters of the EMBA are tropical year-round with
summer sea surface temperatures around 26 C, and winter temperatures around 22 C
(DEWHA 2008).
The oceanography of the EMBA is highly seasonal and is dominated by the movement of
surface currents derived from waters of the Indonesian Throughflow. The influence on the
water column reaches a peak during the austral winter when the southern throughflow is at
its greatest. During summer when the throughflow is weaker, strong winds from the
southwest cause intermittent reversals of the currents, which may be associated with
occasional upwellings of colder, deeper water onto the shelf (Condie et al. 2006). The
Ningaloo Current, flowing northwards, is also thought to intrude into the EMBA during
summer. Tidal activity is also a significant factor as tides contribute to vertical mixing of
surface water layers and sediments.
Turbidity in the NWS is generally greater nearshore during summerapproximately
one Nephelometric Turbidity Units (NTUs)than during winter due to stronger offshore
winds and increased sediment discharges (~6 NTU) (SKM 2012). Elevated turbidity levels
(>80 NTU) are also recorded during cyclonic activity. The waters at the EP location are
characterised as having relatively low turbidity but displaying high temporal and spatial
variability. Fine sediments are often resuspended by ground swell and deeper areas can
become highly turbid near the seabed (Chevron 2010a). Offshore turbidity can also be
influenced by nearshore conditions as the result of tidal, wave action or current induced resuspension and episodic runoff from adjoining rivers.
Salinity in the EMBA typically varies between 34.4 g/L and 36.3 g/L (Chevron 2010b).
Surface salinity may be elevated in summer due to evaporation. Higher salinity is typically
recorded at inshore sites (SKM 2012). Cyclone events may also increase or decrease
salinity to varying water depths depending on the rate of vertical mixing and level of rainfall,
respectively. The EMBA is characterised as having low background concentrations of trace
metals and organic chemicals. The offshore waters are considered oligotrophic (low nutrient
levels) with upwelling of deep nutrient-rich waters being suppressed by the Indonesian
Throughflow and Leeuwin Current.

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Figure 3.1: Environment that may be affected (EMBA) from potential impacts
associated with FCG and hydrotest discharges
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Geomorphology & Benthic Habitats
The EMBA is located on the outer continental shelf in water depths of approximately 120 m,
which gradually slopes from the coast to the shelf break. Figure 3.2 illustrates the spatial
distribution of the various substrates and benthic habitats within the operational area, and is
based on data from both ROV and hydro-acoustic surveys. These habitats were classified
into the following substrate types:
Flat to micro rippled (< 0.5 m)
Silt/sand substrate
Sparse (110 m2) to abundant (50100 m2) bioturbation (evidence of infauna such as
burrows and mounds)
Trace to very sparse (< 1%) benthic sessile and motile invertebrates including soft corals,
sea pens, sponges, sea whips, ascidians, urchins and hydroids.
Seabed sediments of the EMBA were deposited at a relatively slow and uniform rate
comprising of bio-clastic, calcareous and organogenic sediments (Carrigy and Fairbridge
1954). Coarse and medium-grained calcareous sandy sediments dominate to the 100 m
depth contour, with a transition to continental slope silts around 100150 m water depths
(Black et al. 1994). The WP will be constructed on the apex of a large ridgeline
(approximately 11 km long and 3 km wide), which represents a morphologically distinct
seafloor feature within the EMBA (Chevron 2010a). Substrates surrounding the WP are
largely characterised as soft, unconsolidated and relatively homogenous coarse and medium
grained calcareous sandy sediments (Black et al. 1994, DEWHA, 2008; Chevron, 2010a).
As the EMBA is largely characterised by soft, unconsolidated sediments (DEWHA, 2008;
Chevron, 2010a) benthic biotic communities are likely to comprise sparse assemblages of
benthic epifauna, such as bryozoans, echinoids, crustaceans, molluscs and sponges, typical
of the North-West Province (DEWHA, 2008; Chevron, 2010a).
Hard substrates are also present in the EMBA at the WP location, where a large ridgeline
(approximately 11 km long) supports occasional (210%) coverage of a diverse array of
benthic sessile invertebrates, dominated by gorgonians (sea fans and sea whips), sponges
and soft coral (Chevron, 2010a).
3.3
Fish and Marine Fauna
Fish communities of the EMBA are likely to be strongly depth related, indicative of a close
association with benthic habitats (DEWHA 2008). The fish diversity is likely to compose
demersal species such as goatfish, lizardfish, ponyfish and threadfin bream, as well as
pelagic species such as trevally, billfish and tuna.
Marine fauna (including marine mammals, reptiles, birds and sharks) are likely to be present
at the WP location, however there are no known breeding, feeding or aggregation areas
within the EMBA. A search for EPBC Act Protected Matters was conducted for the EMBA
and found a total of nine threatened species; 17 migratory species, 40 marine species and
22 cetaceans were listed as potentially occurring, however only four of these species were
recorded as known from the EMBA, these were the Humpback Whale (Megaptera
novaeangliae); Flatback Turtle (Natator depressus); Giant Manta Ray (Manta birostris) and
Whale Shark (Rhincodon typus). The full list of species identified by this search is provided in
Appendix E.

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Figure 3.2: Classification of the Benthic Habitat within the Operational Area

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ENVIRONMENTAL RISK ASSESSMENT
An environmental risk assessment has been undertaken to evaluate significant impacts and
risks arising the FCGT and dewatering activities. This section summarises the methods used
to assess the environmental risks associated with these activities.
4.1
Risk Assessment Approach
The risk assessment of discharges described under this Plan was undertaken in accordance
with the Chevron Corporate Health, Environment and Safety (HES) Risk Management
Process (Chevron 2012) using the Chevron Integrated Risk Prioritization Matrix. The
approach generally aligns with the processes outlined in Australian Standard/New Zealand
Standard (AS/NZS) ISO 31000:2009 Risk Management and Handbook 203:2012 Managing
Environment-related Risk (Standards Australia/Standards New Zealand 2009, 2012).
The risk assessment process and evaluation involved consultation with environmental
consultants, emergency response and transport professionals as well as installation and
chemical engineers. Risks were identified and informed by:
Experience gained during Wheatstone Construction Environmental Plans
Experience of Chevron Australia personnel involved in other Chevon major projects
Stakeholder engagement.
Physical and ecological, consequences were also informed by:
Experienced in-house environmental and social practitioners
Experienced external specialist environmental consultants
Knowledge of the existing environment, its values, sensitivities, and regional importance
Predictive modelling (e.g. for hydrocarbon spills)
Available scientific and research literature.
The environmental impact identification and risk assessment process comprised the
following components:
Identification of activities and associated aspects with the potential to impact identified
physical, biological, and socioeconomic receptors
Identification of physical, biological, and socioeconomic receptors within the EMBA by
the activities and aspects, and identification of particular environmental values and
sensitivities
Evaluation of the potential consequences to the identified receptors without safeguards
Identification of safeguards to reduce the potential likelihood of the consequence
occurring
Evaluation of the likelihood of the consequence occurring with planned and confirmed
safeguards in place
Quantification of the risk ranking with safeguards in place
Determination of whether the potential environmental impacts and risks are ALARP after
considering the effectiveness of the identified safeguards
Determination of whether the potential environmental impacts and risks are acceptable
Development of environmental performance objectives, performance standards, and
measurement criteria.
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The outcomes of the environmental impact identification and risk assessment process
relevant to this management plan are summarised in Section 4.3.
4.2
Discharge Characterisation
4.2.1
Toxicity
The process of chemical toxicity determination has been developed to establish a threshold
of toxicity for the chemical (Hydrosure 0-3670R) used during the FCGT activities. The
process used the following steps:
Whole of Effluent Toxicity (WET) testing assessing the toxicity of the effluent on a suite
of relevant local species under a range of exposure concentrations using the
recommended protocols from ANZECC and ARMCANZ (2000)
Establishing environmental protection threshold criteria based on ANZECC and
ARMCANZ (2000) guidelines, results from WET testing and software to develop species
protection limits.
WET testing involves exposing organisms to various concentrations of a potentially toxic
medium and then measuring a pre-determined experimental endpoint (e.g. mortality, growth,
or reproductive characteristics) after a selected period of time (ANZECC & ARMCANZ 2000).
WET testing of the proposed flooding fluid was conducted for a mixture of Hydrosure
0-3670R diluted with seawater which was sourced in the vicinity of the trunkline route
(Latitude -21.28850, Longitude 114.51600); and was undertaken using five locally relevant
species from four different taxonomic groups.
Single species WET test laboratory results can be extrapolated to determine the effects in
the wider aquatic ecosystem by investigating the statistical distribution of all of the single
species toxicities. This extrapolation uses the statistical endpoints from the single species
ecotoxicity testing to estimate a species sensitivity distribution (SSD), from which guideline
values for estimating the maximum concentrations at which a given level of species
protection can be achieved (refer Table 4.1).
Table 4.1: Species protection concentrations for Hydrosure 0-3670R based on the
NOEC* SSD from WET testing
Hydrosure
(based on NOEC)
PC99%
(ppm or mg/L)
PC95%
(ppm or mg/L)
PC90%
(ppm or mg/L)
PC80%
(ppm or mg/L)
0.06
0.10
0.15
0.23
* NOEC (No Observed Effect Concentration)
The 99% species protection concentration is suggested by ANZECC and ARMCANZ (2000)
for development of environmental criterion for high conservation ecosystems or chemicals
that have a tendency to bioaccumulate. While Hydrosure 0-3670R has a negligible risk for
bioaccumulation and the EMBA does not occur in a high conservation ecosystem, the 99%
species protection level was selected to ensure the environmental risk assessment
outcomes represented a conservative appraisal of the potential toxicity impacts of the
discharge. This resulted in threshold criteria for modelling expressed as:
Over a 48 hour period, the median concentration of Hydrosure 0-3670R is not to exceed
0.06 mg/L.

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The methodology and results of WET testing, including development of environmental

protection thresholds that were subsequently applied to flooding fluid modelling results, are
described in detail in Appendix D, and the application of these results to modelling of
flooding fluid discharges is presented in Appendix B and described in Section 4.3.
4.2.2
Dispersion
Modelling of the discharge of flooding fluid was conducted to predict the spread of the outfall
plume based on the concentration and duration of the discharge under a range of
climate/oceanographic conditions. The aim of modelling was to predict the environmental
fate (concentration and duration) of flooding fluid discharged at the WP for two discharge
scenarios:
Discharge 1: 20 000 m3 flooding fluid discharged at two metres above sea floor over
20 hours modelled with an assumed Hydrosure 0-3670R discharge concentration of
550 ppm
Discharge 2: 220 000 m3 flooding fluid discharged at -45 m (approximately 30 m above
sea floor) over six to eight days. The first 200 000 m3 modelled with an assumed
Hydrosure 0-3670R discharge concentration of 500 ppm. The last 20 000 m3 modelled
with a conservative Hydrosure 0-3670R discharge concentration of 1000 ppm.
A hybrid application of a near-field expert system (CORMIX) and a quasi-3D Lagrangian
dynamic far-field model (MIKE21 NPA) were applied to assess the dilution characteristics of
the plume. A range of conservative assumptions were applied, and supporting sensitivity
testing was performed, in order to improve confidence that the potential dilution limits have
been captured. Stationary plume characteristics were evaluated using CORMIX to estimate
plume centreline dilutions and plume widths. A customised tool was generated to project
CORMIX plume predictions onto a high-resolution grid. Utilising this tool in combination with
available Acoustic Doppler Current Profiler (ADCP) data near the platform location to define
ambient flow conditions, a full year of quasi-stationary 2D fields was generated within the
region 2 km from the platform for the range of expected flow rates. A more detailed
description of the modelling undertaken for these discharges is provided in Appendix C.
The selected threshold concentration of a 48-hour median concentration of 0.06 mg/L was
used to determine the maximum envelope within which the discharge plume may occur
subject to the likely prevailing metocean conditions at the time of the discharge. Discussion
of the application of this concentration is further described in Section 4.3.2 in the assessment
of potential impacts from the discharge.
As with the development of the threshold criteria, the modelling approach and assumptions
represent a highly conservative appraisal of the dispersion concentrations of the discharge,
some of the conservatisms associated with the modelling include:
Running the model as a continuous effluent release under a range of expected flow rates
over 12 months rather than as a single release of limited duration (68 days)
Basing discharge concentrations on the initial dosing concentration of Hydrosure
0-3670R, without accounting for expected degradation of active ingredients during
residence time in the pipeline.
Representation of all model outputs over the 12 month simulation to identify the total
envelope of possible impacts, which exaggerates the spatial extent of potential impacts.
As a result of the above approach/assumptions, the impact envelopes presented in Figure
4.1 capture the most adverse combination of environmental factors over a full year.

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Whereas, actual discharges under typical ambient conditions for the site can be expected to
generate a significantly smaller impact footprint. In summary the modelling found that:
Under certain conditions median concentrations of the 220 000 m3 flooding fluid
discharge over the 12 month simulation period may exceed the threshold criteria of
0.06 mg/L over a 48 hour period, but as illustrated in Figure 4.1, the results were highly
influenced by seasonal metocean conditions.
In general, for the targeted pigging speed (0.5 m/s) the area in which the discharge
concentration exceeded the threshold criteria over the 12 month simulation period was
very limited, and did not extend beyond 400 m from the discharge point ( 1%
probability).
Where seasonal conditions resulted in low residual currents (May, July and August) and
during high dispersion scenarios, the area in which the discharge concentration
exceeded the threshold criteria over the 12 month simulation period extended up to 800
m from the platform (1% probability).
At a pigging speed of 0.75 m/s (representing the worst case discharge scenario) the area
in which the discharge concentration exceeded the threshold criteria over the 12 month
simulation period extended up to 1.5 km from the platform (1% probability).
For both low and high dispersion settings, during periods of ambient current activity (in
May and August), an atypical plume behaviour is observed which resulted in fingers of
the discharge extend up to 3 km from the platform at concentrations exceeding the
threshold criteria over the 12 month simulation period.

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Figure 4.1: Potential discharge impact envelopes based on a 48 hour median of

0.06 mg/L and typical discharge rate (0.5m/s pigging speed)
4.3
Potential Impacts
Potential impacts associated with the discharge include:

Physical impacts resulting from the temporary suspension and subsequent settlement of
sediments on benthic biota, and
Toxic impacts to benthic and pelagic species resulting from water quality changes.

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Physical impacts
The release of 20 000 m3 flooding fluid at approximately two metres above the seabed will
initially be at a high velocity but will decrease quickly over a short period of time (first 10 to
15 mins). Minor and localised seabed disturbance is anticipated as a result of possible
sediment suspension surrounding the point of discharge. However, as this discharge will be
directed vertically upwards, not towards the seabed; it will rapidly decrease in velocity (within
10 to 15 sec); and will take place on a ridge line comprising mostly hard substrates, the
potential for sediment suspension and associated physical impacts to benthic habitats is
likely to be negligible.
The discharge of 220 000 m3 of flooding fluid 45 m below the sea surface from the
dewatering activities has the potential to result in physical seabed disturbance due to both
the duration (six to eight days) and velocity (between 2.69 m/s and 8.06 m/s), typically, 5.37
m/s is the rate at which it is expected to occur. However, the height of the discharge above
the seabed (30 m) and the presence of the rock blanket below the SGS and predominantly
hard substrates more broadly surrounding the WP are expected to minimise any risk of
scouring and / or a sediment plume.
4.3.2
Toxicity Impacts
WET testing described in Section 4.2.1 demonstrated that the discharge of the flooding fluid
containing Hydrosure 0-3670R has the potential to cause acute toxicity to marine organisms
if present in the immediate surrounds of the discharge at concentrations above 0.06 mg/L.
However, modelling showed that under most circumstances the discharge plume above this
concentration value did not extend beyond 1.5 km.
Based on these findings, there is a reasonable likelihood that marine species that are
present out to a distance of 1.5 km from the discharge point, could experience acute toxic
impacts (both lethal and non-lethal) as a result of exposure to the discharge at
concentrations above the 0.06 mg/L threshold (noting that the 0.06 mg/L threshold
concentration is less than the half the NOEC value for any invertebrate species tested).
WET testing included consideration of impacts to fish and pelagic invertebrate species
however the likelihood of these species being exposed to the discharge at concentrations
higher than the threshold for periods greater than 48 hours is negligible. Furthermore, highly
motile fish and other marine fauna have the capacity to adapt their behaviour in response to
changes in environmental conditions and can be expected to move away from the discharge
if exposed.
Given the limited abundance of benthic habitats and/or biota within the EMBA , the large
area of similar habitat from which re-colonisation may occur, the high reproductive rates of
most benthic invertebrate species; the low likelihood of pelagic species being exposed to the
discharge; and the ability of fish and marine fauna to move away from the discharge plume,
the potential for toxic impacts to occur from the flooding fluid discharge are considered to be
localised, short-term and negligible at the population or bioregional scale.
4.4
Risk Assessment Summary
Based on the combination of consultation, WET testing and dispersion modelling as

described in Sections 4.1, 4.2.1 and 4.2.2, the risk assessment for trunkline (and hence
Flowline) dewatering following FCG and hydrotesting indicate that the risk to benthic habitat
and pelagic species is considered low. A summary of the risk assessment findings for these
discharges is shown in Table 4.2.

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Table 4.2: Summary Risk Assessment outcomes for the dewatering of Trunkline
following FCG and Hydrotesting
Activity
Discharge of
flooding fluid from
storage pond
following hydrotest
3
(20 000 m )
Discharge of
flooding fluid due to
dewatering of
trunkline from
onshore to WP
3
(220 000 m ) during
dewatering activities.

Potential Environmental
Impact
Consequence
Likelihood
Residual Risk
Minor and localised

disturbance to habitat
through sediment
suspension and
settlement.
Incidental (6)
Remote (5)
Low (10)
Temporary and localised

reduction in water quality
resulting in acute toxicity
effects on marine fauna.
Incidental (6)
Unlikely (4)
Low (9)
Minor and localised

disturbance to habitat
through sediment
suspension and
settlement.
Incidental (6)
Remote (5)
Low (10)
Temporary and localised

reduction in water quality
resulting in acute toxicity
effects on marine fauna.
Minor (5)
Unlikely (4)
Low (8)
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5.0
ENVIRONMENTAL MANAGEMENT, MONITORING AND

REPORTING
5.1
Management Measures
This section describes the management actions to be implemented or standards to be

adopted by Chevron to manage environmental risk under this Plan (Table 5.1). They reflect
both the mitigation measures put in place during the design of these activities as well as
potential control measures that can be implemented at the time of discharge, in accordance
with the scenarios modelled.
Table 5.1: FCGT and Trunkline Dewatering Management Actions or Standards
Management Item
Management Action or Standard
Chemical
Selection
Process
A formal chemical selection process (Appendix A) assessed alternative

options for the treatment of the flooding fluid to ensure that the chemical
selected presented:
the lowest practicable environmental risk while meeting requisite
technical performance criteria and HES requirements
a low risk of persistence or bioaccumulation once released into the
marine environment.
Chemical Dosing
Strategy
To optimise concentrations for both technical pipeline integrity and

environmental outcomes dosing will undergo QA/QC to determine final
required chemical concentrations (refer to Section 2.3.2).
Volumes
The volume of flooding fluid released from the storage pond will not exceed
3
20 000 m
The volume of the flooding fluid discharged from the dewatering of the
3
trunkline will not exceed 220 000 m
Concentrations
Discharge Rate
The Hydrosure 0-3670R concentration of flooding fluid (excluding the last

3
20 000 m ) will not exceed a mean concentration of 550 ppm
Trunkline dewatering discharge rate of 220 000 m of flooding fluid will
3
3
remain between 0.22 m /s and 0.68 m /s during dewatering (between
pigging speeds of 0.25 and 0.75 m/s)
3
Discharge rate for the 20 000 m of flooding fluid released from the storage
3
pond will remain below 0.28 m /s during discharge
3
5.2
Marine Fauna
Hazing
Should the discharge occur during the whale migration season (MayOctober) hazing techniques will be employed during day light hours, where
practicable and safe to do so, in an effort to divert whales away from the
EMBA during the discharge. Where practicable and appropriate, hazing
techniques will be consistent with those employed for oil spill response
Triggers and Corrective Actions
The corrective actions and associated triggers included in this plan are focussed on flooding
operations.
Triggers and Corrective Actions for flooding operations include:
The trigger value for flooding fluid which has a shorter residence time in the trunkline
(stabilisation fluid, FCG forewater and water between the pigs) will be a mean
concentration no greater than 385 ppm.
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The trigger value for flooding fluid with a longer residence time (overpump and main
flood) in the trunkline will be a mean concentration no greater than 550 ppm
The trigger value for the re-dosage of flooding fluid stored in the temporary onshore
ponds prior to reinjection will be a mean concentration of 550 ppm (assumes a
concentration of zero ppm in water received from the trunkline at the time of redosing).
Stroke counters and/or flow meters will be used for the chemical injection in combination
with the main line flow meters to ensure the correct dosing of chemicals. Flow rate,
volume of water pumped (position of pig) and volume of chemicals injected
(concentrations) will be logged every 15 minutes while the tank level will be checked
every 30 minutes to confirm the correct amount of chemicals has been injected.
Should the monitoring described above determine that the mean dosage concentration
has exceeded the relevant trigger value, immediate actions will be taken to reduce the
dosage rate to bring the mean concentration below the trigger level.
The primary reasons for adaptive management not being considered for the dewatering
operations are:
During dewatering of the trunkline the discharge flow rate is determined by the pigging
speed which must be controlled to minimise the risk of trunkline obstruction, as such flow
rates cannot be adjusted in response to environmental considerations without significant
risk to the overall operation.
The manufacturer of Hydrosure has developed an in-house test that will be used for
monitoring end-of-pipe concentrations but the Limit of Reporting (sensitivity) of this test is
currently 200 ppm and therefore is not suitable for monitoring the marine environment.
Monitoring of discharge concentrations within the marine environment post-discharge
would require laboratory analysis of water samples collected from within the EMBA to
provide meaningful information. As there is no prescribed and commercially available
laboratory test to detect Hydrosure 0-3670R concentrations and no suitable surrogate
parameter other than Nitrogen that can be monitored laboratory analysis of the discharge
in the marine environment is impracticable.
Even if a suitable water quality test were commercially available, the discharge duration
is expected to be completed in 6 to 8 days, meaning that water sampling and laboratory
analysis would not be completed in time to enable adaptive management measures to
be implemented during discharge operations.
5.3
Monitoring
The monitoring program is designed to support the triggers and corrective actions associated
with flooding operations, however, as no corrective actions are proposed for the dewatering
discharge, infield monitoring of the marine environment at the WP for these precommissioning activities is not proposed.
However a range of operational data will be collected to verify the model outcomes. This
includes collection of operational records (fluid composition, discharge volumes and timing,
and metocean data etc.) as evidence that discharges are consistent with model predictions.
Table 5.2 provides the parameters that will be measured and associated criteria that will be
used to confirm that the discharges are consistent with model prediction. These monitoring
criteria have been developed to determine whether the objectives of the management
actions or standards have been met. Where no practical quantitative target exists, a
qualitative target is set and used.

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Table 5.2: Monitoring Parameters and Criteria

Activity
Parameter
Measurement criteria
Flooding of the
Trunkline during FCGT
activities
Concentration
Dosing records for the flooding fluid injected

during flooding demonstrate a mean
Hydrosure 0-3670R concentration that is
550 ppm or less
Re-dosing records for the flooding fluid stored
in the temporary onshore pond demonstrate a
mean dosage Hydrosure 0-3670R
concentration that is 550 ppm or less
(assumes a concentration of zero ppm in water
received from the trunkline at the time of
redosing)
Discharge of 20 000 m
associated with
dewatering the onshore
pond
Discharge of 220 000 m

Flooding Fluid
Volume
Dewatering records demonstrate no more than

3
20 000 m released
Discharge Pipe
Direction
Inspection of trunkline outlet orientation shows

vertical alignment with a deviation of 30
Discharge Rate
Dewatering records demonstrating a mean

3
average discharge rate is at or below 0.28 m /s
Concentration
Laboratory analysis of end-of-pipe samples

collected at the WP demonstrates that
Hydrosure 0-3670R concentrations in the
flooding fluid at the time of dewatering are
consistent with modelled input parameters.(to
be used for Hind-cast Modelling refer
Section 5.4)
Volume
Dewatering records demonstrate no more than

3
220 000 m released
Discharge Rate
Dewatering records demonstrating discharge

3
3
rate between 0.22 m /s and 0.68 m /s during
dewatering
Marine Fauna
Observers
For the duration of trunkline dewatering

activities Marine Fauna Observers (MFOs) will
be used during day light hours to record the
presence of marine fauna within 1500 m of the
discharge location
For the duration of trunkline dewatering
activities, MFOs will also record any
observations of fish or mass fish mortality that
are observed during day light hours within
1500 m of the discharge location
Metocean data

Metocean conditions will be monitored in the

vicinity of the WP to collect data on wind,
wave, tidal, surface and residual current
conditions as well as water temperature and
salinity. Metocean data will be collected prior
to, during, and following the discharge to
confirm that metocean conditions at the time of
the discharge are consistent with the input
parameters used for the model
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Hind-Cast Modelling
Hind-cast modelling will be conducted to amalgamate metocean, engineering and flooding

fluid water quality data into an integrated hind-cast dispersion model. The dispersion model
will be re-run after the completion of trunkline dewatering using end-of-pipe Hydrosure
0-3670R concentration measurements, recorded or estimated flow rates, confirmed as-built
outfall configuration and actual metocean conditions at the time of discharge. Some model
assumptions used in the forecast model may be adjusted based on field validation work. The
modelling will estimate the direction, dispersion and potential persistence of median
Hydrosure 0-3670R concentrations above the threshold criteria of 0.06 mg/L to demonstrate
the point after the completion of discharges when conditions are returned to baseline levels.
5.5
Reporting
A Commonwealth annual Compliance Assessment Report (CAR) is required as per

Condition 3 of EPBC 2008/4469. The report will assess compliance against Ministerial
conditions within the compliance reporting period being 31 August to 30 August of each
compliance year, with the CAR due by 30 November of each year.

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REFERENCES
ANZECC & ARMCANZ (2000) Australian and New Zealand Guidelines for Fresh and Marine
Water Quality. Australian and New Zealand Environment and Conservation Council
and Agriculture and Resource Management Council of Australia and New Zealand,
National Water Quality Management Strategy Paper 4, Canberra, ACT
Black, K., Brand, G., Grynberg, H., Gwyther, D., Hammond, L., Mourtika, S. Richardson, B.,
Wardrop, J. 1994. Production Activities. In Environmental implications of offshore oil
and gas development in Australia The findings of an independent scientific review,
edited by J. Swan, J. Neff and P. Young, 209-407. Sydney: Australian Petroleum
Exploration Association
Carrigy, M. A. and Fairbridge, R W., 1954. Recent sedimentation, physiography and
structure of the continental shelves of Western Australia, 38, 65-95
Chevron. 2010a. Draft Environmental Impact Statement/Environmental Review and
Management Programme for the Proposed Wheatstone Project. Chevron Australia
Pty Ltd. Perth, Western Australia
Chevron. 2010b. Gorgon Gas Development and Jansz Feed Gas Pipeline: Coastal and
Marine Baseline State and Environmental Impact Report: Offshore Feed Gas Pipeline
System and Marine Component of the Shore Crossing. Chevron Australia Pty Ltd,
Perth, Western Australia. (G1-NT-REPX0002749)
Chevron. 2012. HES Risk Management U&G GOMBU Standardized OE Process. Chevron
Australia Pty Ltd, Perth, Western Australia.
Condie, S. A. and Dunn, J. R. (2006). Seasonal characteristics of the surface mixed layer in
the Australasian region: implications for primary production regimes and
biogeography. Marine and Freshwater Research, 57:569590
Department of the Environment, Water, Heritage and the Arts (DEWHA, now known as
DOTE) 2008. North-west Marine Bioregional Plan Bioregional Profile: A Description of
the Ecosystems, Conservation Values, and Uses of the North West Marine Region.
Canberra: Government of Australia. Available online at:
<http://www.environment.gov.au/coasts/mbp/publications/north-west/bioregionalprofile.html>
Department of Sustainability, Environment, Water, Population and Communities (SEWPaC,
now known as DOTE) 2012. Marine bioregional plan for the North-West Marine
Region prepared under the Environment Protection and Biodiversity Conservation Act
1999. Department of Sustainability, Environment, Water, Population and
Communities. Available online at:
<http://www.environment.gov.au/coasts/marineplans/north-west/pubs/north-westmarine-plan.pdf> [Accessed 26 March 2013]
SKM. 2012. Water Quality baseline measurement programme: Twelve monthly baseline
water quality measure report: 15/05/2011 to 21/05/2012. Report to Chevron Australia
Standards Australia/Standards New Zealand. 2004. ISO 14001:2004 Environmental
Management Systems Requirements with Guidance for Use. Sydney/Wellington:
Standards Australia/Standards New Zealand

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Standards Australia/Standards New Zealand. 2009. ISO 31000:2009 Risk Management

Principles and Guidelines. Sydney/Wellington: Standards Australia/Standards New
Zealand
Standards Australia/Standards New Zealand. 2012. HB 203:2012 Environmental Risk
Management Principles and Process. Sydney/Wellington: Standards
Australia/Standards New Zealand
URS Australia Pty Ltd. 2009b. Macedon Gas Development Assessment of Drilling Fluid, Drill
Cutting and Hydrotest Fluid Discharges from the Macedon Gas Field. Report
Prepared for BHP Billiton Petroleum Pty Ltd. Perth, Western Australia

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Appendix A Chemical Selection Process

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CHEMICAL SELECTION PROCESS
Chemical treatment of the flooding-fluid is recommended to protect the integrity of the

trunkline by preventing microbial growth leading to corrosion within the pipeline through the
effective use of biocide. Since biocides are by their very nature designed to be toxic to
marine biota, they are classified as High Hazard Category chemicals according to the
Chevron Hazardous Materials Approval Process (Appendix C). As a result the chemicals
considered for the treatment of the trunkline flooding fluid were subject to a detailed review
and selection process. The chemical selection process examined all relevant information to
demonstrate that planned discharges meet ALARP and Acceptability criteria. The process
involved four key analysis steps:
1.
Treatment Options Analysis
2.
Chemical Options Analysis (including Chemical Screening)
3.
Chemical Approval
4.
Endorsement of Selected Option.
The Chevron Hazardous Materials Approval Procedure is designed to assess the hazardous
properties of a broad spectrum of chemicals, not just biocides. The criteria used for
assessment under this procedure confirm that chemicals used as marine growth inhibitors
(biocides) will be assessed as being highly hazardous chemicals causing potential
environmental harm due to their intended toxicity. The Chevron Hazardous Materials
Approval Procedure was therefore used as the third step in the chemical selection process
as a pre-screening tool to eliminate any chemical treatments that contained constituents
which were either banned by legislation and/or the Chevron Environmental Stewardship
Process or which presented the potential risk of persistence or bioaccumulation once
released into the marine environment.
A1.0
Treatment Options Analysis
The trunkline will be flooded for hydrotesting as part of the FCGT activities. To identify leaks
during hydrotesting, Fluorescein Dye was selected for use as a leak detection dye.
Fluorescein Dye was selected due to its low toxicity, availability, low cost, water solubility and
stability, and ease of detection. In addition, rapid breakdown of Fluorescein Dye following
exposure to sunlight suggests that concentrations likely to be encountered by these
organisms in the field would be low (Walthall and Stark 1999). Fluorescein Dye is routinely
used in offshore petroleum projects.
The trunkline is constructed by welding together mild steel pipe sections internally coated
with Pipegrad P100 to prevent corrosion. The welded-joints are not coated and are exposed
to the flooding fluid. This flooding fluid can contain corrosive oxygen, and bacterial species
that support microbiologically influenced corrosion, which are both detrimental to carbon
steel and the internal integrity of the pipeline. Therefore treatments that limit the effect of
corrosive oxygen and bacteria were considered for the flooding-fluid. The following treatment
options were identified:
1. Seawater treated with oxygen scavenger and exposed to Ultra Violet (UV) light
2. Deoxygenated freshwater
3. Seawater treated with oxygen scavenger and the biocide Tetrakishydroxymethyl
phosphonium sulphate (THPS)

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4. Seawater treated with oxygen scavenger and the biocide Glutaraldehyde

5. Seawater treated with Hydrosure 0-3670R, a proprietary hydrotest chemical
containing oxygen scavenger and biocide (Quaternary Ammonium Chloride Salts
(Quats).
Each option contained its own technical, commercial, health and safety, and operational
challenges that were considered in conjunction with the potential environmental impacts
associated with discharging the flooding fluid into the marine environment.
Option 1
The option of seawater treated with oxygen scavenger and exposed to UV light for bacterial
sterilisation was not considered acceptable to prevent internal corrosion and ensure trunkline
integrity. The effectiveness of UV sterilization to kill bacteria species is affected by particulate
shadowing, therefore it cannot provide an absolute sterilisation solution. This option is not
suitable for long-term wet storage of pipelines as there is no residual treatment action and
there is a potential lag-time required to validate the effectiveness of this method of treatment.
Option 2
The use of deoxygenated freshwater in place of seawater was eliminated as an option due to
the large volume of freshwater required, specifically that it would need to be supplied
continuously to the WP during the FCGT activities.
Options 3, 4 and 5
The remaining three options involved treatment of seawater with biocide. The flooding fluid
would be seawater that is filtered and treated with a biocide and oxygen scavenger.
Seawater was selected as it is readily available in the operational area and will be released
back into the marine environment adjacent to the trunkline prior to commissioning.
A2.0
Chemical Options Analysis
The following three chemicals were considered as biocide treatments for the filtered
seawater:
THPS (tetrakishydroxymethyl phosphonium sulphate)
Glutaraldehyde
HydrosureTM 0-3670R (Quaternary Ammonium Chloride + Oxygen Scavenger).
Information on the three biocide options was gathered to compare their performance against
a list of assessment criteria, including effectiveness of integrity preservation and
performance; health and safety impacts and application as well as the environmental
hazardous properties of the chemicals i.e. their ecotoxicity, biodegradation and
bioaccumulation potential. A detailed assessment was conducted using manufacturerprovided information and published literature. The three biocide options were taken from
chemical vendor treatment recommendation submitted by Baker Petrolite and Champion
Technologies. A comparison of key chemical characteristics including half-lives, ecotoxicity
(including residual toxicity), biodegradability and bioaccumulation for Hydrosure 0-3760R,
THPS and Glutaraldehyd, respectively, is shown in Table A 1.

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Table A 1: Comparison of published test data on persistence, acute and chronic ecotoxicity, biodegradability, bioaccumulation and concentration characteristics of
chemical treatment options
Published Data
THPS
Glutaraldehyde
Hydrosure
Concentration
300 ppm
300 ppm
350 ppm
Acute Toxicity
94 119
12
1.0
0.413
0.032
0.004
72 days
@ pH 7
63.8 days
@ pH 9 25C
379 days
@ pH 9
Inherently
biodegradable
Readily biodegradable.
Biodegradation is
inversely proportional
to alkyl chain length.
Rainbow Trout, 96 hrs

LC50 (ppm)
Chronic Toxicity
Daphnia, 21 days
NOEC (ppm)
Persistence
(Abiotic half-life)
Biodegradability
Highly water soluble

with a low volatility
Degradation occurs by
a combination of
hydrolysis, oxidation,
photo-degradation and
biodegradation
Bioaccumulation
Does not
bioaccumulate
Breaks down to simple

molecules (carbon
dioxide and water)
through the natural
action of oxygen,
sunlight, bacteria and
heat.
Degradation rate or
half-life varies
depending on the pH
and temperature
Does not
bioaccumulate
Degradation rate or
half-life in seawater is
58 days for typical
solutions, but can be
more than 15 days
when the alkane chains
are predominately C16.
No major persistent
metabolites are known
for the active
substances.
Moderate potential to
bioaccumulate in
freshwater fish
Data sourced from:

1. Dow AQUCAR (Water Treatment Microbiocides) - Oil & Gas Biocide Selection Guide
Glutaraldehyde, THPS & Quaternary Amine Microbiocides Chemistries)
2. DOW Product Safety Assessment: gluteraldehyde. Revised:April11,2013
3. Baker Hughes :- Safety Data Sheet - XC24380
4. Baker Hughes :- Safety Data Sheet - XC24105
5. Champion Technologies :- Safety Data Sheet - Hydrosure O-3670R
6. Champion Technologies: CTLP-PLP-059 Monitoring Method O-3670R (Draft)\
7. Reregistration Eligibility Decision for Alky Dimethyl Benzyl Ammonium Chloride (ADBAC)
(Comparing
The assessment of Hydrosure 0-3670R required the use of surrogate information due to
incomplete data for this proprietary product at the time of assessment. The surrogate
information was for similar active components in Hydrosure 0-3670R, namely Quaternary
Ammonium Chloride (ADBAC) The Material Safety Data Sheet (MSDS) for Hydrosure
identifies the quaternary ammonium chloride as CAS No. 68424-85-1, which is
Benzalkonium Chloride or synonym ADBAC and Ammonium Bisulphate, considered
appropriate analogues for the hazardous action of the whole product. The performance and
hazard ranking of each biocide option was assessed with regard to meeting the necessary

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performance criteria. Summaries of the assessment findings are presented in Table A 2,

Table A 3 and Table A 4.
Table A 2: Option 3 - THPS Performance and Implementation Summary
Biocide
Advantages
Use of an
oxygen
scavenger
and THPS
THPS is a
highly reactive
biocide and is
unlikely to
persist in the
environment
when
discharged.
Oxygen scavenger requires

between 15 seconds to
48 hours reaction time in
advance of biocide injection.
Non bioaccumulative
and inherently
biodegradable
(or
biodegradable).
At 30 C THPS has a half-life

close to 40 days. The trunkline
will experience temperatures up
to 32 C, therefore a very high
dose of THPS is required to
maintain pipeline integrity for 12
to 36 months.
THPS 75% is
ranked GOLD
on the OCNS
(CEFAS,
2013).
Disadvantages
At higher concentrations (>500

ppm) THPS can lower the pH of
fluids to below 4, which can
lead to corrosion of mild steel.
Residual toxicity effect on the

environment initially when
released, as it is a biocide.
The OCNS ranking carries a
substitution warning (CEFAS,
2013).
Summary of findings
Oxygen scavenger reacts directly
with proposed biocide and must
be injected well before the
biocide. The oxygen scavenger
needs to have totally reacted
before the biocide can be
injected. A time range of between
15 sec to 48 hrs is noted in
literature as being required for the
oxygen scavenger to react before
the biocide is added.
For a 12 to 36 months plus
protection duration, injection of
more than 500 ppm of THPS is
required.
Long term THPS contact with
Carbon Steel causes pitting
corrosion, which could lead to
loss of pipeline integrity.
The trunkline could remain flooded for a period of 12 to 36 months at an immersion water
temperature of 32 C, so a dose of more >500 ppm of THPS would be needed to achieve the
optimum microbial influence corrosion protection. This concentration of THPS would lower
the fluid pH to a level considered unacceptable, therefore eliminating THPS as a biocide
treatment option.

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Table A 3: Option 4 - Glutaraldehyde Performance and Implementation Summary

Biocide
Use of an oxygen
scavenger and a
glutaraldehyde
Advantages
Disadvantages
Glutaraldehyde
is Non bioaccumulative
and biodegradable.
Oxygen scavenger
requires between 15
seconds to 48 hours
reaction time in
advance of biocide
injection.
Comprehensive chemical inhibition and

treatment of filtered seawater is only
achieved, if the oxygen scavengers have
fully reacted. Should a full reaction not
be achieved the biocide component will
be neutralised and deactivated.
Complex chemical
injection methodology,
which requires
additional equipment
and operating
personnel.
The added system complexity required

to minimise the risk of biocide
neutralisation increases the risk of
incorrectly treating the seawater, which
may result in overdosing thus
increasing the environmental impact and
offshore duration to complete the works.
Glutaraldehyde
50% is ranked
GOLD on the
OCNS and
carries no
substitution
warnings
(CEFAS, 2013).
Requires large
volumes of chemicals
to be stored and
handled offshore as
over 1200 ppm of the
product would need to
be applied to maintain
pipeline integrity for 12
to 36 months.
Requires the reduction
in PIG velocity during
discharge events.
Residual toxicity effect
on the environment
initially when released,
as it is a biocide.
Summary of findings
A 200% additional volume of chemical is

required to treat the same volume of
filtered seawater, compared to
Hydrosure 0-3670R thus increasing HSE
risks associated with transportation and
containment during mobilisation and
offshore execution.
Availability of large volumes of these
chemicals is limited resulting in
additional schedule risk.
Increased equipment spread and
additional operational needs require
larger offshore support vessels.
To minimise the risk of inadequate
chemical inhibition and air inclusion,
which will affect pre-hydro test
stabilisation, a reduction in the average
PIG velocity to 0.35 m/s during
discharges will be required, extending
the offshore execution duration, costs
and additional environmental impact
(emissions and discharges) due to
extended vessel presence in the field.
The health and safety issues associated with handling and use of glutaraldehyde, the
increased equipment spread, and the reaction caused by incompatibility with oxygen
scavenger, eliminated glutaraldehyde as a biocide chemical treatment option.

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Table A 4: Option 5 - Hydrosure 0-3670R (Quaternary Ammonium Chloride Salt)

Performance and Implementation Summary
Biocide
Advantages
Disadvantages
Summary of findings
Use of a chemical
blend which
contains an
oxygen
scavenger,
biocide
(Quaternary
Ammonium
Chloride Salt)
and a small
amount of
surfactant
Hydrosure 0-3670R can

be applied as one
product and does not
require a time lag as
with a separate oxygen
scavenger and biocide.
Residual toxicity
effect on the
environment
when initially
released, as it is a
biocide.
Simplified offshore injection

methodology, equipment spread
not complex and commonly
executed within the industry.
Temperatures up to
150 C do not affect the
product which enables a
lower concentration
(ppm) to be used than
other assessed
biocides.
OCNS ranking
carries a
substitution
warning (CEFAS,
2013).
Reduced volume of chemical

required to treat the same volume
of filtered seawater, compared to
other assessed biocides, thus
significantly reducing HSE risks
associated with transportation and
containment during mobilisation
and offshore execution.
Exhibits surfactant
properties which act as
a corrosion inhibitor to
protect the carbon steel
surface from corrosion.
Simplified offshore
equipment spread.
Biodegradable and nonbioaccumulative
Hydrosure 0-3670R is
ranked GOLD on the
OCNS (CEFAS, 2013).
Hydrosure 0-3670R active biocide component (Table A 5) has a longer half-life when
compared to the other biocides. The half-life allows Hydrosure 0-3670R dosage at a lower
concentration and makes it desirable for long-term pipeline integrity preservation. Hydrosure
0-3670R is a one-part product, which does not involve the mixing of two incompatible
products with an injection time-lag to limit incompatibility reaction as for THPS and
Glutaraldehyde.
Table A 5: Chemical composition of Hydrosure 0-3670R
Chemical
Formula
Composition
Coco benzyldimethylammonium chloride

(Quaternary Ammonium)
C22H40ClN
1030 %
Ammonium Bisulphite
NH4HSO3
1030 %
Dipropylene Glycol Methylether
C7H16O3
110 %
Ethanediol
C2H6O2
<1 %
H2O
3050 %
Water

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The application advantages of using a product containing both biocide and oxygen
scavenger, together with the additional corrosion inhibition properties to protect the carbon
steel weld sections, makes Hydrosure 0-3670R the preferred option for treatment of the
filtered seawater.
A3.0
Chemical Approval
Hydrosure 0-3670R was screened using the Chevron Hazardous Materials Approval
Procedure (HMAP). An overview of the procedure can be found in Appendix C. The HMAP is
designed to:
Assess Hazardous Materials requested for procurement for their HES risks and provide
an opportunity for selection and procurement of less hazardous chemicals (substitution),
where reasonably practicable
Ensure that appropriate controls are identified for the use of procured Hazardous
Materials and communicated to the requestors of the materials and end users.
Step 1 Treatment Options Analysis (Section A1.0) and Step 2 Chemical Options Analysis
(and screening) (Section A2.0) were completed prior to the HMAP being conducted so all of
the relevant information could be provided to demonstrate the process which had been
undertaken to arrive at the selected chemical and to provide information that is not usually
included as part of an MSDS. The HMAP was used to get an independent assessment of the
selected chemical to ensure the selected chemical meets all the requirements outlined in
Steps 1 (Section A1.0) and 2 (Section A2.0).
A4.0
Endorsement of Selected Option
A workshop was completed involving Chevron Environment, Construction, Subsea Flowlines

and Pipeline Engineering, and Management to review the selected chemical. The workshop
discussed how the decision to select the chemical was arrived at, and why it was the most
feasible in meeting project requirements. The criteria considered as part of the final chemical
selection decision were that the chemical option selected must:
Be technically robust and safe to implement offshore, with minimal risk to personnel or
pipeline integrity
Be industry proven and readily available to support commencement of pipe-lay by Q1
2014 (schedule subject to change)
Have a confirmed preservation period of 12 to 36 months to avoid the potential for
contingency dewatering and re-flooding
Be screened through the internal Chevron HMAP which includes the Environmental
Chemical Assessment Tool
Reduce health, environment and safety risks to ALARP at the proposed discharge
locations
Meet the Projects FCG specification requirement which includes maintaining pipeline
integrity.
Hydrosure is considered biodegradable and non-bioaccumulative. Testing of analogous
products (ADBAC) which contain the same active substances as Hydrosure are reported to
have a half-life of between 8 and 15 days in seawater and are considered to be highly
biodegradable. This indicates that the potential persistence of Hydrosure in marine water and
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sediments is unlikely. Further, Bioconcentration factor (BCF) testing of ADBAC reported BCF
values for fish of 79 L/Kg (Centre for Environment, Fisheries & Aquaculture Science [CEFAS]
Chemical Hazard and Risk Management [CHARM] OCNS Grouping: GOLD).
Bioconcentration is the process by which a chemical substance is absorbed by an organism
from the ambient environment through its respiratory and dermal surfaces (Arnot and Gobas
2006). Substances with a BCF reported below 1000 L/Kg are considered to not
bioconcentrate (Champion Technologies. 2013)). Bioaccumulation is analogous to BCF, but
applies to field measurements or to laboratory measurements with multiple exposure routes
(USGS 2013).
Given that ADBAC is considered an appropriate surrogate, the data suggests that the active
substances in Hydrosure 0-3670R do not bioconcentrate. Bio-accumulation of Hydrosure
0-3670R was investigated under the CEFAS CHARM system. The evaluation of Hydrosure
0-3670R ranked the product as non-bioaccumulative on the basis that it has a Log Pow <3
(GOLD ranking) for Coco benzyldimethylamonium chloride (Quaternanry ammonium
compound).
Impacts to water quality from the metabolites of Hydrosure are also considered to be short
term, localised and negligible as the chemical composition of Hydrosure (refer Section A2.0)
is mostly comprised of carbon, nitrogen and oxygen.
Hydrosure 0-3670R was considered the most viable chemical treatment option due to the
following factors:
Provides significantly greater pipeline integrity performance than the alternatives (options
3 and 4)
Has a longer half-life reducing the risk of potential contingency dewatering and reflooding should the pipe-lay schedule be extended
Provides better HES performance than the alternatives (less likelihood of reflooding
requirements and therefore fewer and reduced duration of vessels in the operational
area)
Provides greater operational performance and reduced logistic requirements (smaller
chemical volumes and vessel requirements compared to the alternatives)
The product is biodegradable and has a negligible risk for bioaccumulation.
Hydrosure 0-3670R offers the optimum solution in terms of preservation of pipeline integrity,
operational implementation and practicality, Health and Safety and commercial
differentiators.

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Appendix B Overview of the ABU Hazardous

Materials Approval Procedure

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APPENDIX B
OVERVIEW OF THE ABU HAZARDOUS MATERIALS
APPROVAL PROCEDURE
The ABU Hazardous Materials Approval Procedure (HMAP) falls under the Chevron
Australia Hazardous Materials Communication Process and applies only to procured
Hazardous Materials, a collective term for those chemical materials/products that are
classified as Hazardous Substances or Dangerous Goods (DG).
The HMAP is designed to:
Assess Hazardous Materials requested for procurement for their HES risks, and provide
an opportunity for selection and procurement of less hazardous chemicals (substitution),
where reasonably practicable
and
Ensure that appropriate controls are identified for the use of procured Hazardous
Materials and communicated to the requestors of the materials and end users at
locations within Chevrons Area of Operations.
The main steps and tools used with the HMAP include:
Use of a Hazardous Material Approval Application Form (HMAAF) to request chemical
HES assessment and approval for acceptability of HES risk prior to purchasing a
material. The HMAAF identifies the proposed uses of the material and exposure
pathways for personnel, and is accompanied by a compliant MSDS as per legal and
company requirements.
A team of nominated HES and DG chemical reviewers reviews each application for HES
risks and compliance with DG licensing requirements.
The first step in the HES review in the HMAP is to verify that the requested material does
not contain ingredients which are listed on the companys Prohibited list of chemicals.
The ABU also maintains a Restricted list of chemical ingredients, which are typically
higher consequence ingredients, which may be used subject to more rigorous controls
being in place. The Restricted and Prohibited lists are derived from company
requirements which are based on national HES regulations and international conventions
(e.g. ozone depleting substances, etc.). Chemicals which contain ingredients on the
companys Restricted and Prohibited lists are either (a) in the case of prohibited
chemicals, rejected or (b) for restricted chemicals approved for use with conditions in
accordance with legal requirements.
Certain requests involving materials with a reasonable potential to be discharged to the
environment, undergo a detailed hazard assessment using an internally developed
assessment tool. The tool ranks the inherent chemical environmental hazardous
properties against six hazard rankings aligned with the Chevron Risk Management
Process RiskMan2 Risk Prioritisation Matrix. Inherent chemical environmental hazards
assessed in this step include acute and chronic eco-toxicity, biodegradability,
bioaccumulation, as well as additional considerations such as composition, waste
disposal options and requirements, safety and risk phrases. The assessment is carried
out by suitably qualified environmental professionals.
Chemicals that are assessed to be in the High Hazard Category (and in some cases in the
Moderate Hazard Category) are challenged and chemical requestors have to either
demonstrate a solid business case for the selected chemical (e.g. technically the best
chemical for the proposed application and no suitable less hazardous alternative) or else
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propose alternative chemicals that are technically suitable for the job, but have lower
inherent environmental and health and safety hazards.
The HMAP is supported by the ChemAlert system, which:
Is used to process the chemical requests
Serves as a register of MSDSs
and
Records the approval conditions and any restrictions that may apply.
The HMAP described above is a high level protocol that nonetheless represents the top of
the hierarchy of risk controls pyramid as applied to chemicals management in the company,
i.e. substituting the hazard (with a less hazardous product). It also identifies additional
controls (that sit lower on the risk control hierarchy) that are applied to chemicals throughout
their life cycle including transportation, storage, use and disposal, as reflected in other HES
management documents (e.g. management plans, operating procedures, job hazard
analyses, permits to operate etc.).
A1.0
Hazardous Material Environmental Assessment and Associated Tools
The environmental assessment aspect of the Hazardous Materials Approval Procedure,

along with description of the supporting tools, is summarised in the following paragraphs and
Figure B 1.
The key supporting tools of the environmental assessment are the CVX Prohibited List of
Materials (Table B 1), the Environmental Hazardous Properties Assessment Table (Table B
2) and the Rule-sets for Adjustment for Environmental Performance Table (Table B 3). The
Environmental Hazardous Properties Assessment Table provides criteria against which the
chemical can be ranked according to 6 ranking bands (6 being the lowest hazard and 1
being the highest hazard band). The criteria cover three key inherent chemical properties:
Persistence, Bioaccumulation potential and Toxicity (PBT). A tabulation of Additional
Considerations such as Risk Phrases/ Hazard Statements, Waste Management and
Disposal and the Offshore Chemical Notification Scheme (OCNS) ranking against the 6
ranking categories is provided as a guide only; these are not used to rank the chemical but
may provide useful benchmarking information to the assessor.
Using the Environmental Hazardous Properties Assessment Table (Table B 2), chemicals
are initially ranked based on their Toxicity using the scale provided. A final rating is derived
by adjusting the initial ranking according to the adjustment criteria provided for Persistence
and Bioaccumulation Potential (Table B 3).

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Figure B 1: Environmental Assessment of Chemicals within the Hazardous Materials

Approval Procedure

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Table B 1: Chevron List of Prohibited Materials

Prohibited Material
Prohibited Material Definition
Effective January 1, 2009 the procurement of new materials or any equipment (new or used)
containing materials listed below is prohibited (Ref. CVX Waste Management Environmental
Performance Standard):
Ozone-Depleting
Substances (ODSs),
as defined by the
Montreal Protocol
Specific chemicals that have been defined by the Montreal Protocol as

having adverse effects on the stratospheric ozone layer. They include
Chlorofluorocarbons (CFCs) (CFC 11, 12, 13, 111, 112, 113, 114, 115, 211,
212, 214, 215, 216, and 217); Halon 1211, 1301, and 2402;
hydrobromofluorocarbons (HBFCs); carbon tetrachloride, 1, 1, 1trichloroethane and methyl bromide. Includes bromomethane.
The CVX List of Prohibited Materials exceptions for ODSs include:
ODSs that have been designated as essential use chemicals by local
government and are exempt from the requirements of the Montreal
Protocol shall be excluded from the Prohibited Materials restrictions for
the operating facility where the government exemption applies.
Hydrochlorofluorocarbons (HCFCs) are not included in the list of
Prohibited Materials under ODSs. Although defined under some
regulatory regimes as ODSs, they have less impact on stratospheric
ozone than CFCs. They have been introduced as temporary
replacements for CFCs.
Hydrofluorocarbons (HFCs) are not included in the list of Prohibited
Materials under ODSs. They were introduced as alternatives to ozone
depleting substances in serving many industrial, commercial, and
personal needs. HFCs are emitted as by-products of industrial processes
and are also used in manufacturing. They do not significantly deplete the
stratospheric ozone layer.
All forms of asbestoscontaining products
Any material containing more than 1% asbestos. While not an exhaustive

list, the following products may fall into this category: pipe-covering,
insulating cement, insulating block, asbestos cloth, gaskets, packing
materials, thermal seals, refractory and boiler insulation materials, transite
board, asbestos cement pipe, fireproofing spray, joint compound, vinyl floor
tile, ceiling tile, mastics, adhesives, coatings, acoustical textures, duct
insulation for heating, ventilation and air conditioning (HVAC) systems,
roofing products, insulated electrical wire and panels, and brake and clutch
assemblies.
Lead-based paint
Any paint containing lead
Polychlorinated
biphenyls (PCBs) and
PCB-contaminated
materials
PCBs are employed in industry as heat exchange fluids, in electric

transformers and capacitors, and as additives in paint, carbonless copy
paper, sealants and plastics. PCB-contaminated materials are defined as
materials exceeding 50 mg/kg of PCB oil.
Leaded thread
compound (pipe dope)
Pipe dope containing lead

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Table B 2: ABU Environmental Hazardous Properties Assessment Table

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Table B 3: Rule-sets for Adjustment for Final Ranking

Increase ranking
by 2 levels (e.g.
from 4 to 6)
Increase ranking
by 1 level (e.g.
from 4 to 5)
Substance is
readily
biodegradable
(rankings 6, 5)
and is non-bioaccumulative
(rankings 6, 5, 4)
Substance is
inherently
biodegradable
(rankings 3, 4)
(rankings 6, 5, 4)
Do not adjust
initial ranking
Decrease
ranking by 1
level (e.g. from 3
to 2)
Decrease
ranking by 2
levels (e.g. from
3 to 1)
Substance is not
biodegradable
(rankings 1, 2)
(rankings 6, 5, 4),
or
Substance is
inherently
biodegradable
(rankings 3, 4)and
bio-accumulates
(rankings 3, 2, 1)
Substance does
not biodegrade
(rankings 1, 2)
and bioaccumulates
(rankings 3, 2, 1)
Substance is
readily
biodegradable
(rankings 6, 5)
and bioaccumulates
(rankings 3, 2, 1)
Depending on the final adjusted ranking, chemicals are grouped into the following hazard
categories:
Low Environmental Hazard Chemicals those with a Final Adjusted Ranking of 6 or 5.
Moderate Environmental Hazard Chemicals - those with a Final Adjusted Ranking of 4 or
3.
High Environmental Hazard Chemicals - those with a Final Adjusted Ranking of 2 or 1.
Approval or challenging of the chemical approval application will depend on the Hazard
Category of the chemical (Low, Moderate or High) and the other considerations listed in
Figure B 1. The assessment results and the decision (approve or challenge) are recorded on
the Chemical Environmental Hazard Assessment Form and submitted to ChemAlert.
Note that approval of chemicals proposed for use in discharges to the environment, is only
part of the risk management process for the discharge. Demonstration of risk acceptance for
the planned discharge will be required in consideration of other factors such as discharge
location and its environmental sensitivities, rate of discharge, etc. and an overall assessment
of potential impacts on the environment.

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Additional Uses of the Environmental Hazardous Properties

Assessment for Chemicals
The Hazardous Materials Environmental Assessment Form (HMEAF) in the HMAP is also
being used as an environmental hazard acceptability screening tool in chemical selection
and planning for both Operations and Major Capital Projects (see Figure B 2). The screening
exercise helps Operations and Project personnel screen out High Hazard chemicals, if
possible to do so, and carry forward into detailed planning only Low and Moderate Hazard
chemicals. Specifically, the Chemical Environmental Hazard Assessment Tool can be used
in the following contexts (see also Figure B 2):
Review and approval of the Hazardous Material prior to purchase through the ChemAlert
System as described in the Overview of the ABU HMAP
and
Screening assessment and selection of the least hazardous chemical for a specific
application as part of operational planning (as per the requirements of the ABU Chemical
Selection and Use Environmental Performance Standard).

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Figure B 2: Intended Use and Application of the Chemical Environmental Hazard

Assessment Tool for ABU Operations and Major Capital Projects

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Appendix C Modelling Report

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APPENDIX C
MODELLING FOR THE DEWATERING OF
FLOODING FLUID
A1.0
Introduction
Modelling of the discharges of flooding fluid was conducted to predict the spread of the
outfall plume based on the concentration and duration of the discharge under a range of
climate/oceanographic conditions. The aim of modelling was to predict the environmental
fate (concentration and duration) of flooding fluid discharged at the WP (refer to Section 2.3
of the Plan). The following sections describe the modelling discharge scenarios, input,
methodology and results. These are described in full in the modelling report provided (DHI
2014).
A2.0
Discharge Scenarios
The summary of key discharge characteristics is provided in Table C 1 and Table C 2.

Table C 1: Key characteristics of modelled discharge scenario (20 000 m3)
Property
Value
Wheatstone Platform coordinates
GEO: (115.38395, -19.92938)

MGA-50: (330 860 m, 7 795 520 m)
Ambient water depth
72 m
Discharge elevation
+2 m above seabed
Discharge geometry
124.5 mm ID pipe, vertical upward
Total volume
20 000 m
Discharge duration
20 hours
Discharge rate
0.278 m /s
Port area
0.0122 m
Port velocity
22.8 m/s
Chemical released
Hydrosure, 550 mg/L
Effluent buoyancy
Neutral
Table C 2: Key characteristics of modelled discharge scenario (220 000 m3)

Property
Value
Wheatstone Platform coordinates
GEO: (115.38395, -19.92938)

MGA-50: (330 860 m, 7 795 520 m)
Ambient water depth
71.5 m
Discharge elevation
-45 m LAT
Discharge geometry
0.326 mm ID pipe, vertical downward
Total volume
220 000 m
Discharge duration
68 days

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Pigging Speed
0.25 m/s to 0.75 m/s, typical 0.5 m/s
Discharge rate
0.224 m /s to 0.672 m /s, typical 0.448 m /s
Port area
0.0834 m
Port velocity
2.69 m/s to 8.06 m/s, typical 5.37 m/s
Waste constituent
Hydrosure, 500 mg/L for 200,000 m followed by

3
916 mg/L for 20,000 m
Effluent buoyancy
neutral
The neutral buoyancy of the discharges is based upon the fact that the discharge will be
predominantly composed of seawater from the WP area 12 to 36 months earlier. While small
temporal variations in salinity or temperature are possible due to seasonal changes or outer
shelf variability, fundamentally the seawater discharged will be consistent with ambient
seawater at the discharge site.
A3.0
Model Inputs
Data sources used as inputs to the model, and used in some cases for extensive model
validation, are shown in Table C 3.
Table C 3: Model Input data
Data
Source
Bathymetry
Local surveys, digital nautical charts accessed via DHIs software MIKE-CMAP and satellite imagery. Additional detail from the 250 m resolution
gridded bathymetric/topographic database established by Geosciences
Australia.
Winds
Modelled wind fields from the Australian Bureau of Meteorologys numerical

weather predictions system, MesoLAPS/Access-A and measured winds at
Onslow meteorological station.
Sea levels
A tide (high resolution pressure) gauge attached to a rigid mooring at

roughly 0.15 m ASB, recorded data once per minute from May 2009 Nov
2010.
Currents
A bottom mounted Teledyne RDI 300 kHz workhorse ADCP was deployed
from May 2009 Nov 2010 at a height of 4.6 m above seabed.
Salinity and
temperature
2 Conductivity Temperature Depth (CTD) casts at two separate locations

close to the platform location recorded at 74 m depth on 10 Nov 2009 and
03 Nov 2010 combined with near bottom temperature data from tide gauge
and ADCP instruments near the bottom and long term Sea Surface
Temperature (SST) from National Oceanic and Atmospheric Administration
(NOAA).

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Methodology

dynamic far-field model (MIKE21 NPA) was applied to assess the dilution characteristics of
the flooding fluid plume. The near-field assessment, performed using CORMIX is designed to
provide baseline information about mixing processes due to the simple outfall geometry, and
to assess coupling options between the near-field and far-field models. The far-field model
has been implemented through a combination of the depth-integrated MIKE21 NHD
hydrodynamic model and the quasi-3D Lagrangian (particle tracking) model MIKE21 NPA..
The Lagrangian particle tracking model (MIKE21 NHD) is a method for calculating the
trajectories of discrete particles in a flow field. The displacement of each particle is assumed
to consist of two components: an advective deterministic component and an independent,
random Markovian component, which statistically approximates the random or chaotic nature
of turbulence in natural flows.
The modelling methods were designed to use a quasi-3D Lagrangian far-field model to
provide a reasonable set of results for a base discharge scenario, from which the results
could be scaled to provide a bounding envelopes for the impact areas with due consideration
of the range of potential discharge rates which may in practice occur. The base discharge
scenario is determined for the middle estimate of 0.5 m/s pigging speed. As such, impact
areas for 0.75 m/s pigging speed are inferred by upscaling the 0.5 m/s pigging speed results,
and impact areas for 0.25 m/s pigging speed are inferred by downscaling the 0.5 m/s results.
A range of conservative assumptions, including seawater stratification, flow conditions and
buoyancy of the discharge, were applied and supporting sensitivity testing performed in order
to improve confidence that the potential dilution limits were captured (refer to DHI 2014a and
2014b). The plume characteristics were first assessed using the near-field expert system
CORMIX for a range of ambient flow conditions, assuming a neutrally buoyant effluent. A
customised tool was generated to project CORMIX-predicted plume geometries onto a highresolution grid surrounding the WP. The dynamic plume response, including pooling during
flow reversals and the medium-term build-up of concentrations in the vicinity of the WP, was
then assessed using the MIKE21 NPA model.
Achievement of the environmental criterion (Appendix D) is driven by the influences of plume
dispersion and plume mobility. As the plume travels away from the WP it will dilute,
increasing the size of footprint in the process. In the vicinity of the WP, the plume closely
weathervanes with the instantaneous current direction.
Due to the lack of certainly around timing of the discharge, an a priori determination of
representative or worst-case evaluation periods is difficult. Further, the residual current
climate is such that particles very rarely remain within the model for longer than 8 days. The
model therefore assesses a continuous discharge over a full calendar year, rather than the
actual limited duration of 20 hours for the 20 000 m3 discharge and 6 to 8 days for the
200 000 m3 discharge. To account for potential variations in pigging speed during the
220 000 m3 discharge, resulting in minor changes to the discharge rate, results from a typical
discharge rate were scaled up. The model results were interrogated hourly to assess
whether the 48-hr running median of Hydrosure concentration exceeded 0.06 mg/L. By
example, if at time X the 48 hr running median concentration is larger than 0.06 mg/L, this
would be recorded as one hour of exceedance. The final results are presented as impact
envelopes, which capture the most adverse combination of environmental forcing over a full
year. Discharges under typical ambient conditions for the site can be expected to generate a
smaller impact footprint.

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A5.0
Modelling results
A.5.1
Near-field (CORMIX) Modelling
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An initial screening assessment was performed based upon the extracted 10th, 50th and
90th percentiles from the annual distribution of current speed, assuming neutrally buoyant
effluent and a uniform ambient density. The CORMIX setup excludes wind, considers an
unbounded domain, and applied a roughness index of 0.025 (Mannings n). The simulations
were run for a total distance of 5000 m downstream of the release point. In order to assess
the impacts due to the variability in pigging speed/flowrate, the model results were scaled
from the typical conditions (0.5 m/s pigging speed) to the maximum (0.75 m/s) and minimum
(0.25 m/s) conditions. The three ambient current conditions induce quite different responses
in the plume. Under most conditions, the effluent reaches the seabed and dissipates its
remaining momentum as lateral spreading within 1 km of the outfall location.
At low discharge rates (0.25 m/s pigging speed) and 90% ambient current speeds, the plume
does not reach the bottom within 1 km of the outfall location. For both the 10% and 50%
current speeds, the plume does reach the bottom within 50 m and 500 m, respectively. For
the typical discharge rate corresponding to a 0.5 m/s pigging speed, all conditions result in
the plume interacting with the bottom. For the high discharge rate corresponding to a
0.75 m/s pigging speed, all conditions result in the effluent reaching the seabed. From these
results, it is seen that at 1000 m, downstream of the outfall location, the dilution and size
(half-width) of the plume under the typical and maximum pigging speed conditions are
similar.
As expected, the maximum discharge rates corresponding to the 0.75 m/s pigging speeds
show the largest impact area and the minimum discharge rates show the smallest impact
area. Of note is that the typical discharge impact area is almost as large as that shown for
the maximum discharge rate. The individual shafts of exceedances tend to be determined
by specific periods of residual currents, typically neap tide, which set in one direction for long
enough to hold the plume within one directional band. Results are shown in Table C 4, Table
C 5 and Table C 6 for 0.25 m/s, 0.5 m/s and 0.75 m/s pigging speeds respectfully.
Table C 4: Near-field dilution and plume dimensions from CORMIX with a pigging
speed of 0.25 m/s
Current Speed
Percentile
Speed (m/s)
Distance from
Discharge (m)
Dilution Factor
Plume
Half-width (m)*
50
90
11
100
140
15
200
261
21
10%
0.10
500
816
46
1000
2400
99
50
51
3.1
100
77
3.9
50%
0.25
200
120
4.8
500
350
14
1000
1400
28
50
39
2.1
100
59
2.5
90%
0.45
200
87
3.1
500
150
4.0
1000
220
4.9
* All CORMIX width definitions converted here to B = distance from centreline to 37% of the centreline
concentration

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speed of 0.50 m/s.
Current Speed
Percentile
Speed (m/s)
Distance from
Discharge (m)
Dilution Factor
Plume
Half-width (m)*
50
30
2.4
100
56
4.4
200
120
9.3
10%
0.10
500
370
30
1000
970
77
50
64
4.9
100
140
12
50%
0.25
200
2200
15
500
510
23
1000
1200
39
50
53
3.3
100
81
4.2
90%
0.45
200
120
5.1
500
460
15
1000
1100
23
concentration
speed of 0.75 m/s.
Current Speed
Percentile
Speed (m/s)
Distance from
Discharge (m)
Dilution Factor
Plume
Half-width (m)*
50
24
2.8
100
43
5
200
85
10
10%
0.10
500
260
31
1000
660
78
50
73
11
100
99
12
50%
0.25
200
150
15
500
340
23
1000
790
39
50
61
4.9
100
120
9.4
200
230
13
90%
0.45
500
450
18
1000
920
26
concentration
As an initial diagnostic exercise, and as a reality check of the dynamic far-field assessment
to follow, the CORMIX-predicted plume geometries have been processed into a long-term
quasi-stationary series of concentration fields within a 2 km square area around the platform.
This provides a simple and transparent means of assessing the balance between the
expansion of the plume footprint due to dilution with the spatial variability induced by rapidly
changing ambient current conditions. The outputs of these projections are shown in Figure C
1, Figure C 2 and Figure C 3.
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Figure C 1: Number of hourly instances for which the median Hydrosure

concentration exceeds 0.06 mg/L over 48 hr duration for a pigging speed of 0.25 m/s,
based upon quasi-stationary CORMIX results projected onto a 2D grid


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Several useful conclusions regarding plume behaviour in the vicinity of the platform can be
drawn from the CORMIX analyses:
Plumes are narrow and tend to be well above the trigger level of 0.06 mg/L of Hydrosure.
However, the combination of narrow plume widths and high directional variability means
that the 48 hr median criteria are only triggered very close to (<~200 m) the platform.
an increase in the estimated rate of plume dilution will tend to increase the size of the
resulting impact areas.
The shape of the impact area tends to be controlled by residual rather than tidal currents.
Extents of impact areas for typical (0.5 m/s pigging speed) and maximum (0.75 m/s
pigging) speeds are similar (as predicted with near-field tools)
A.5.2
Far-field (MIKE21 NPA) Modelling
The primary output of the NPA model is the time-varying instantaneous concentration field of
particles. In this application the NPA model output has been saved in multiple resolutions,
due to the differing plume geometries near and at distance from the platform. Close to the
platform the horizontal and vertical plume dimensions are small, and small integration
volumes are required to avoid excessive over-dilution due to insufficient resolution. At
distance from the platform, the plume dimensions increase but the particle cloud also
disperses and can become sparsely populated, which necessitates larger integration
volumes. Figure C 4 illustrates the evolutionary behaviour of the plume by showing daily
instantaneous concentrations at midday during each day of a 12 day period in August 2009,
The model is then run for a full year (May 2009 Apr 2010), in one month increments. Each
simulation starts on the first day of the given month, and concludes at the end of the fourth
day of the following month. This provides for an overlap to account for the warm-up period
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at the start of each simulation, and to avoid transitional gaps in the coverage of the running
median calculations. Far field modelling results are processed from the 45 m x 20 m
resolution NPA output area, and are provided for the base simulations as well as low and
high dispersion sensitivity tests. The outputs of the model therefore show cumulative monthly
plots of the daily median concentrations over a 12 month period.
From the model outputs, it is clear that higher dispersion results in elevated exceedance
frequencies close to the Platform, and much smaller frequencies at distance from the
platform, while concentrations above the threshold occurred at the greatest distance from the
WP when seasonal weather presented calm metocean conditions and under higher
dispersion settings.
Taking into account all months, model results for the 220 000 m3 discharge indicated that
violations of the 48 hr median threshold where primarily confined to areas within 400 m of the
platform (1% exceedance) for the base case discharge rate and dispersion settings. Areas
outside of this 400 m area (<1% exceedance) were shown to have potential for fingers to
extend out to as far as 3 km. Sensitivity testing of higher and lower dispersion settings within
the NPA model showed the potential for a larger impact radius of up to 3 km. The 1%
exceedance for this case extended up to approximately 800 m from the platform.
The model was scaled and interrogated under base case, minimum and maximum expected
discharge rates (pigging speed) and varying far-field dispersion settings. Footprints for the
maximum discharge rate corresponding to a 0.75 m/s pigging speed indicated total footprints
could extend up to 3.5 km from the platform. The 1% exceedance footprint extended up to
1.5 km from the platform . The results from the modelling of the 20 000 m3 discharge showed
that, while instantaneous values exceeded 0.06mg/L, the 48-hour median criterion was not
exceeded at any time or under any dispersion scenario modelled.
The results of this analyses showed specifically that discharges which took place during the
months of May, July and August, where there was the least current movement, exhibited a
significantly greater impact footprint than the other months. Figure C 5, Figure C 6 and
Figure C 7 illustrate the range of potential dispersion scenarios that are predicted by the
model for the 220 000 m3 discharge under the simulated pigging speeds and dispersion
settings.

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Figure C 4: Illustration of plume behaviour over 12 consecutive days between Aug 3

and Aug 16, 2009, inclusive

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Figure C 5: Monthly exceedance of the 0.06 mg/L 48-hour median criterion at the WP
location at low pigging speed and under low dispersion settings

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location at base pigging speed and under base dispersion settings

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location at high pigging speed and under high dispersion settings

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Conclusions
dynamic far-field model (MIKE21 NPA) is applied to assess the dilution/plume characteristics
of the trunkline water discharged from the WP the plume. The resulting plume dilution fields
are compared to the calculated environmental compliance criterion. Modelling of the base
dispersion for the 220 000 m3 discharge indicated that 1% exceedance of the 48-hour
median threshold is confined to areas within 800 m of the WP under typical conditions.
Sensitivity testing of higher and lower dispersion settings and higher pigging speeds shows
the potential for a larger impact radius of up to 3.5 km for any exceedence, and 1.5 km
where there was 1% exceedance. Modelling of the 20 000 m3 discharge indicated no
exceedances of the 48-hour median threshold.
These conclusions are generated under the conservative assumption of a continuous
effluent release rather than one of limited duration and are based on the initial dosing
concentration of Hydrosure, without accounting for expected degradation of active
ingredients during residence time in the pipeline. While this is useful for identifying the
envelope of possible impacts, it may in many cases exaggerate those impacts.

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Appendix D Whole of Effluent Toxicity (WET)

Testing

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APPENDIX D
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WET TESTING
Subsequent to the conclusion of the chemical selection process described in Appendix A

Whole Effluent Toxicity (WET) testing was conducted on Hydrosure 0-3670R (Champion
Chemicals Pty Ltd) to identify the potential toxicity of the effluent following discharge to the
marine environment. Toxicity of Hydrosure 0-3670R was evaluated using product obtained
from the manufacturer, diluted in seawater obtained from the Wheatstone operational area. A
series of dilutions of the Hydrosure 0-3670R in seawater were prepared to test a range of
product concentrations in order to determine the relative toxicity to individual species.
Measures of toxicity from all of the test species were combined to develop environmental
performance objectives, standards and measurement criteria for comparison with the
anticipated concentrations of the flooding fluid at the time of flooding (500 ppm of Hydrosure
0-3670R). These assumptions do not take into account any degradation of the active
constituents within the hydrotest flooding fluid while held within the pipe.
A1.0
WET Testing Methods
WET testing involves exposing organisms to various concentrations of an effluent or flooding

fluid and then measuring a pre-determined experimental endpoint (e.g. mortality, growth, or
reproductive characteristics) after a selected period of time (ANZECC & ARMCANZ 2000).
WET testing was conducted on Hydrosure 0-3670R diluted with seawater and the dilution
water was sourced from waters in the vicinity of the trunkline route (Latitude -21.28850o,
Longitude 114.51600o). The water was collected directly from an onsite vessel in accordance
with ANZECC & ARMCANZ (2000) procedures for water sampling. Water samples were
packed in ice and sent via air freight directly to the NATA accredited ecotoxicity testing
laboratory (Ecotox Service Australasia). Full details of the ecotoxicity methodology are
presented in Chevron Australia (2013a).
WET testing was undertaken on five locally relevant species from four different taxonomic
groups using the recommended protocols from ANZECC and ARMCANZ (2000). The
Wheatstone marine project development area lies at the southern extent of NWS marine
region which is considered to represent tropical waters as classified by IMCRA 4.0
(Commonwealth of Australia 2006). The waters in this region contain both tropical and
temperate organisms so the selection of species from both regions for WET testing was
considered relevant. WET testing included mostly tropical species from a range of trophic
levels (primary producer, herbivore and carnivore), where chronic (where available) and
acute tests for toxicity were applied.
WET tests were conducted using two experimental components. The first being a range
finding test in which the effective concentration range for each experimental end-point and
species was determined. Once the effective concentration range was determined, the
definitive ecotoxicological assays were conducted over this concentration range to capture
the complete dose response relationship. Since Hydrosure 0-3670R is a mixture containing
both the oxygen scavenger and the biocide for chemical treatment, only one assay in each
test species was necessary to evaluate the toxicity of the product.
Concentration range varied depending on the test species and experimental end-point. The
concentrations used for each test can be found in (Table D 1). In all experiments, the ratio of
concentrations selected was relative to the following proportions: 100, 50, 25, 12.5 and
6.25 %. Four replicates (N=4) were used in all experiments for each test concentration.

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Table D 1: Whole Effluent Toxicity Testing of Hydrotest Medium Discharges in

Commonwealth Waters
Species
Test
Type
End-Point
Temp C
Conc.
Nitzschia
closterium (Algae)
72 hr Growth
Inhibition
Chronic
Saccostrea
echinata (Mollusc)
48 hr Larval
Abnormality
Chronic
Normal
development
rate
29 1
31.32000.0
g/L
Heliocidaris
tuberculata
(Echinoderm)
72 hr Larval
Development
Chronic
Normal
development
rate
20 1
78.15000.0
g/L
Melita plumulosa
(Crustacean)
96 hr Acute
Toxicity
Acute*
Survival
20 1
0.031.00
Lates calcifer
(Fish)
96 hr Acute
Toxicity
Acute*
Cell yield
21 1
0.210.0
mg/L
mg/L
Imbalance
25 2
6.3100.0
mg/L
*ACR=10, where ACR is the Acute to Chronic Ratio used as a divisor for transformation of acute values into
chronic test values.
Two main procedures are currently used for developing single species toxicity measures
based on these ecotoxicity tests, hypothesis testing and point estimation techniques.
Hypothesis testing using Dunnett's test (Dunnett 1955) compares each test concentration in
order to determine the lowest test concentration that is significantly different from the dilution
water control (the Lowest Observed Effect Concentration - LOEC); the No Observed Effect
Concentration (NOEC) is then inferred to be the highest test concentration below the LOEC.
Point estimation techniques use regression analysis of the dose response curve to derive a
figure such as ECp (Effect Concentration), the concentration that causes a stated effect in p
percent of the test organisms.
There is debate over the appropriateness of each estimate of single species toxicity when
extrapolating results to the wider aquatic ecosystem; however the prevailing guidance in
ANZECC and ARMCANZ (2000) appears to advocate the use of NOEC (hypothesis tested).
Both endpoints have been reported in the presentation of results. Test results for locally
relevant species used for the WET testing program are described in Table D 2. Chronic tests
were selected where available for that taxonomic group.

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Table D 2: WET testing results for flooding fluid / medium treated containing
Hydrosure
Species
Duration
(hrs)
Nitzschia
closterium
(Algae)
72
Saccostrea
echinata
(Mollusc)
48
Heliocidaris
tuberculata
(Echinoderm)
72
Melita
plumulosa
#
(Crustacean)
96
Lates calcifer
#
(Fish)
96
EC10
(mg/L)
1.5 *
EC50
(mg/L)
3.3
LOEC
(mg/L)
NOEC
(mg/L)
2.50
1.30
0.50
0.250
2.50
1.25
0.25
0.13
25.0
12.5
(3.03.58)
0.29
0.54
(0.240.33)
(0.520.56)
1.30
1.71
(1.271.32)
(1.701.74)
0.08
0.14
(0.040.11)
(0.100.16)
13.5
17.5
(12.318.0)
(17.118.0)
*95% confidence limits are not reliable; Numbers in brackets represent the 95% fiducial limits.
#
Toxicity test is defined as an acute test.
Single species toxicity assessments for flooding fluid, Hydrosure 0-3670R, showed toxicity in
all species tested. This result was expected given that the active substances of the chemical
treatment (oxygen scavenger and biocide) are designed to interfere with natural (bio)chemical processes. For Hydrosure the species rank toxicity (NOEC) from most observed
toxicity to least was: crustacean > oyster (mollusc) > sea urchin (echinoderm) = microalgae >
fish.
A2.0
Environmental Criteria
Environmental criteria have been developed to be applied to a discharge of a large volume of

flooding fluid (approximately 220 000 m3) over a duration of approximately 6 - 8 days.
Discharges associated with other activities are significantly smaller and for a shorter
duration. Application of the same environmental criteria to these smaller discharges can be
viewed as a more conservative approach.
Single species WET test laboratory results can be extrapolated to effects in the wider aquatic
ecosystem using a risk based approach. By investigating the statistical distribution of all of
the single species toxicities, guideline values can be developed to estimate the maximum
concentrations unlikely to cause adverse environmental effects. Environmental criteria to be
applied to the discharge were developed from the results of WET testing (Table D 2) using
the recommended methods in ANZECC and ARMCANZ (2000), with the three following
modifications:
1.
The ANZECC and ARMCANZ (2000) trigger development methods are intended
for application to long-term outfalls that result in chronic effects, with long-term
continuous exposure. Any NOECs derived from an acute toxicity test (Melita
plumulosa and Lates calcarifer in the current tests) can be converted to a chronic
value by dividing by the ACR. The discharge of flooding fluid is not a chronic

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2.
3.
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discharge (approximately 192 hrs at approximately -40 m LAT) so an acute

toxicity trigger is more appropriate. Therefore the ACR was not applied to the
acute toxicity test results; test results defined as chronic were retained for use
without transformation.
Effluent toxicity is based on a concentration by time interaction. There are some
difficulties in extrapolating results from a laboratory (where concentrations can be
maintained throughout the duration) to application in the field (where
concentrations at a single point will vary over time depending on the metocean
conditions). For this reason, the best available approach for a concentration that
varies over time was to compare the fixed laboratory value with the median field
concentration of the chemical over a defined duration.
As a methodology for chronic discharge, the triggers developed using the
ANZECC and ARMCANZ (2000) guidelines do not specify a prescribed duration
of exposure. Again this is not appropriate for a short term exposure of a
potentially acutely toxic discharge, as is the case here. It is appropriate that if an
acute intensity trigger is to be used, this must be associated with specific
exposure duration. The durations of exposures in the laboratory tests ranged from
4896 hrs. The discharge will be subject to hydrodynamic conditions that result in
higher median concentrations over short durations than at longer durations.
Therefore the most conservative approach (i.e. the highest median value in the
field) is to establish an exposure duration for trigger comparison based on the
minimum test duration, in this case 48 hrs
The latest available version of the BurrliOZ software (TclPro Application V8.3.2, last
modified: 25 July 2001; Copyright 2000 Ajuba Solutions) supplied with the National Water
Quality Management Strategy Paper No. 4 package (ANZECC & ARMCANZ 2000) was used
to analyse the ecotoxicity of Hydrosure 0-3670R. The NOEC values were used as the
statistical endpoints from the single species ecotoxicity testing for estimation of the species
sensitivity distribution (SSD), fitted using BurrliOZ. Full details of the methodology are
included in MScience (2013). Calculation of environmental criteria for the flooding medium
using the SSD and raw NOEC values are presented in Table D 3.
Table D 3: Species protection concentrations for Hydrosure 0-3670R based on the
NOEC SSD from WET testing
Hydrosure
(based on NOEC)
PC99%
(ppm or mg/l)
PC95%
(ppm or mg/l)
PC90%
(ppm or mg/l)
PC80%
(ppm or mg/l)
0.06
0.10
0.15
0.23
The 99% species protection concentration is suggested by ANZECC and ARMCANZ (2000)
for development of environmental criterion for high conservation ecosystems or chemicals
that have a tendency to bioaccumulate. This would result in an environmental criterion trigger
of 0.06 mg/L (or ppm). Since Hydrosure 0-3670R has a negligible risk for bioaccumulation
the 95 % level of species protection may also be applied. In this instance the environmental
criterion trigger would be 0.10 mg/L (or ppm). These criteria have been developed for chronic
discharges and do not recognise the duration of the exposure to the flooding fluid.
In order to establish a conservative environmental criterion for application in Commonwealth
waters, the data from Table D 3 and the three modifications listed above were applied. The
environmental criterion applied to modelling and assessment was therefore defined as
follows:
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Over a 48 hour period, the median concentration of Hydrosure 0-3670R is not to exceed
0.06 mg/L.
As the Commonwealth Conditions for approval (EPBC/2008/4469) do not define spatial
zones of environmental protection, this criterion applies to all spatial points around the
discharge. Since the concentration of Hydrosure 0-3670R in the flooding fluid is 500 ppm,
significantly greater than 0.06 ppm, there is no scenario in which the discharge will be able to
comply with this environmental criterion at all locations and times around the discharge. As
such, this criterion will be used to interrogate the results of the modelling to define a mixing
zone, outside of which the environmental criterion will be considered to have been met.
As Hydrosure 0-3670R has a negligible risk for bioaccumulation (Appendix A) and the
discharge is to occur over a short period (less than 192 hrs), no additional environmental
criteria have been set.
Unpublished data for the degradation profile for Hydrosure 0-3670R during a 12 month field
simulation test shows approximately 20% reduction in activity over 12 months at 10 C
(Figure D 1). Based on this data, the application of the results of the WET testing program to
develop environmental criteria is considered to represent a conservative approach. That is,
while the Hydrosure toxicity to local species remains constant (e.g. the environmental
criterion), the concentration of the toxic components in the flooding fluid discharge
(e.g. those used in the modelling) will likely be reduced from the concentrations known at the
time of flooding (i.e. 500 ppm). Therefore the extent of the mixing zone defined by modelling
is predicted to be larger than the actual mixing zone during discharge.
Figure D 1: Hydrosure 0-3670R degradation profile (source: Champion Technologies

2011)
In addition to Hydrosure 0-3670R, the flooding medium is also planned to contain
Fluorescein dye (50 ppm). The ecological information in the Fluorescein MSDS report the
product is not expected to be hazardous to the environment (Champion Technologies 2011)
and estimates of the lethal concentration of sodium fluorescein solution (Walthall and Stark
1999) were higher than the concentrations proposed for use in FCGT activities of the
trunkline (50 ppm). Based on the routine use of Fluorescein in offshore projects, WET testing
and environmental criteria were not considered relevant for this compound.
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Appendix E EPBC Matters of National

Environmental Significance
EPBC Status: E = Endangered, V = Vulnerable, Mi= Migratory, Ma = Marine, C = Cetacean
Common Name
Scientific Name
EPBC Status
Occurrence
Cetaceans
Blue Whale
Balaenoptera musculus
Mi
Humpback Whale
Megaptera novaeangliae
Mi
Known to occur
Antarctic Minke Whale
Balaenoptera bonaerensis
Mi
May occur
Bryde's Whale
Balaenoptera edeni
Mi
May occur
Killer Whale
Orcinus orca
Mi
May occur
Sperm Whale
Physeter macrocephalus
Mi
May occur
Spotted Bottlenose Dolphin
Tursiops aduncus
Mi
May occur
Common Dolphin
Delphinus delphis
May occur
Pygmy Killer Whale
Feresa attenuata
May occur
Short-finned Pilot Whale
Globicephala macrorhynchus
May occur
Risso's Dolphin
Grampus griseus
May occur
Pygmy Sperm Whale
Kogia breviceps
May occur
Dwarf Sperm Whale
Kogia simus
May occur
Melon-headed Whale
Peponocephala electra
May occur
False Killer Whale
Pseudorca crassidens
May occur
Spotted Dolphin
Stenella attenuata
May occur
Striped Dolphin
Stenella coeruleoalba
May occur
Long-snouted Spinner Dolphin
Stenella longirostris
May occur
Rough-toothed Dolphin
Steno bredanensis
May occur
Bottlenose Dolphin
Tursiops truncatus
May occur
Cuvier's Beaked Whale
Ziphius cavirostris
May occur
May occur
Sharks
Great White Shark
Carcharodon carcharias
Mi
May occur
Whale Shark
Rhincodon typus
Mi
Known to occur
Shortfin Mako
Isurus oxyrinchus
Mi
Likely to occur
Longfin Mako
Isurus paucus
Giant Manta Ray
Manta birostris
Likely to occur
Mi
Known to occur
Seabirds and Migratory Shorebirds

Pandion haliaetus
Ma
May occur
Three-keel Pipefish
Campichthys tricarinatus
Ma
May occur
Pacific Short-bodied Pipefish
Choeroichthys brachysoma
Ma
May occur
Pig-snouted Pipefish
Choeroichthys suillus
Ma
May occur
Reticulate Pipefish
Corythoichthys flavofasciatus
Ma
May occur
Roughridge Pipefish
Cosmocampus banneri
Ma
May occur
Banded Pipefish
Doryrhamphus dactyliophorus
Ma
May occur
Osprey
Bonyfish

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Common Name
Scientific Name
EPBC Status
Occurrence
Bluestripe Pipefish
Doryrhamphus excisus
Ma
May occur
Cleaner Pipefish
Doryrhamphus janssi
Ma
May occur
Tiger Pipefish
Filicampus tigris
Ma
May occur
Brock's Pipefish
Halicampus brocki
Ma
May occur
Mud Pipefish
Halicampus grayi
Ma
May occur
Spiny-snout Pipefish
Halicampus spinirostris
Ma
May occur
Ribboned Pipehorse
Haliichthys taeniophorus
Ma
May occur
Beady Pipefish
Hippichthys penicillus
Ma
May occur
Western Spiny Seahorse
Hippocampus angustus
Ma
May occur
Spiny Seahorse
Hippocampus histrix
Ma
May occur
Spotted Seahorse
Hippocampus kuda
Ma
May occur
Flat-face Seahorse
Hippocampus planifrons
Ma
May occur
Hedgehog Seahorse
Hippocampus spinosissimus
Ma
May occur
Tidepool Pipefish
Micrognathus micronotopterus
Ma
May occur
Pallid Pipehorse
Solegnathus hardwickii
Ma
May occur
Gunther's Pipehorse
Solegnathus lettiensis
Ma
May occur
Robust Ghost Pipefish
Solenostomus cyanopterus
Ma
May occur
Rough-snout Ghost Pipefish
Solenostomus paegnius
Ma
May occur
Double-end Pipehorse
Syngnathoides biaculeatus
Ma
May occur
Bentstick Pipefish
Trachyrhamphus bicoarctatus
Ma
May occur
Straightstick Pipefish
Trachyrhamphus longirostris
Ma
May occur
Reptile
Loggerhead Turtle
Caretta caretta
Mi
Ma
Likely to occur
Green Turtle
Chelonia mydas
Mi
Ma
Likely to occur
Leatherback Turtle
Dermochelys coriacea
Mi
Ma
Likely to occur
Hawksbill Turtle
Eretmochelys imbricata
Mi
Ma
Likely to occur
Flatback Turtle
Natator depressus
Mi
Ma
Known to occur
Olive Seasnake
Aipysurus laevis
Ma
May occur
Spectacled Seasnake
Disteira kingii
Ma
May occur
Olive-headed Seasnake
Disteira major
Ma
May occur
Fine-spined Seasnake
Hydrophis czeblukovi
Ma
May occur
Elegant Seasnake
Hydrophis elegans
Ma
May occur
Spotted Seasnake
Hydrophis ornatus
Ma
May occur
Yellow-bellied Seasnake
Pelamis platurus
Ma
May occur

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Offshore Facilities and Produced Formation

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ACRONYMS, ABBREVIATIONS AND TERMINOLOGY

Micrograms per Litre

Acute to Chronic Ratio

Alky Dimethyl Benzyl Ammonium Chloride

Acoustic Doppler Current Profiler

Ashburton North Strategic Industrial Area

Australian and New Zealand Environment and Conservation Council

Agriculture and Resource Management Council of Australia and New Zealand

Compliance Assessment Report

Centre for Environment, Fisheries & Aquaculture Science

Chemical Hazard and Risk Management

Dampier-to-Bunbury Natural Gas Pipeline

DBP Development Group Pty Ltd

Department of the Environment - formerly Department of Sustainability,

The Environmental Impact Statement/Environmental Review and Management

Environment that may be Affected

Environmental Protection Act 1986

EPBC Act (Cth)

Environment Protection and Biodiversity Conservation Act 1999

The Commonwealth Primary Environmental Approval and conditional

Flooding, Cleaning And Gauging

Flooding, Cleaning, Gauging and Testing

Health, Environment and Safety

Chevron Australia Pty Ltd

Hazardous Material Approval Application Form

Hazardous Materials Approval Procedure

Liquefied Natural Gas

Lowest Observed Effect Concentration

Metres per second

Marine Discharge Management Program

Milligrams per litre

Material Safety Data Sheet

Million Tonnes Per Annum

Marine habitat from the 20 m contour to the shoreline

No Observed Effect Concentration

Offshore Facilities and Produced Formation Water Discharge Management Plan

Offshore Petroleum Greenhouse Gas Storage (Environment) Regulations 2009

Offshore Facilities and Produced Formation Water Discharge Management

Parts per million

Nearshore and offshore marine facilities, trunkline, and onshore facility

Chevron Australia Pty Ltd

Species Sensitivity Distribution

Tetrakishydroxymethyl phosphonium sulphate

Whole of Effluent Toxicity

Chevron Australia Pty Ltd

Chevron Australia Pty Ltd

Figure 1.1: Planned Location of Project Infrastructure

Chevron Australia Pty Ltd

Offshore Facilities and Produced Formation Water Discharge Management

Water quality targets based on the ANZECC Water Quality Guidelines

Chevron Australia Pty Ltd

Chemical Selection Process

Treatment Options Analysis.

Chevron Australia Pty Ltd