red gully care & maintenance

Red Gully Care & Maintenance

Environment Plan

Ref: EGO-HSE-RGPF-EP-001

Rev 8 of 124

Issued: 28/05/2018

Document Number EGO-HSE-RGPF-EP-001 Page 1 of 124

Red Gully

Care & Maintenance

Environment Plan

(includes C&M of Red Gully North-01)

EGO-HSE-RGPF-EP-001

Red Gully C&M Environment Plan

Document Number EGO-HSE-RGPF-EP-001 of 124

Distribution List

Company Position Location

DMIRS EARS Online

Empire Oil Company (WA) Limited

General Manager

Mineral Resources LTD Perth Office Operations Manager

Safety Manager

Upstream PS Site Office Red Gully Pipeline & Processing Facility

8 28/05/2018 EP Performance Standards amended as per DMIRS request

A Wills P Reynolds A Walker

7 11/04/2018/ EP revised to address DMIRS queries

A Wills V Hinkley A Walker

6 2/03/2018 EP revised to include Red Gully North-01 and reflect operations transition into C&M

A Wills V Hinkley A Walker

5 14/12/2017 Revised and updated Chemical disclosure and associated SDS

V Hinkley R Hill A Walker

4 11/12/2017 Revised and updated as per DMIR request

Chemical Disclosure

Humeceptor

Leach Drain

Performance Standards

V Hinkley R Hill A Walker

3 17/11/2017 Revised and updated with previous Bridging Documents and details for Well Activities

A Badri V Hinkley A Walker

2 06/07/2017 Revised and updated as per DMIR request

V Hinkley J Mastrocinque K Aitken

1 28/6/2017 Revised and updated as per DMP request


0 29/05/2017 Revised as per DMP request


New Document Number [EGO-HSE-RGPF-EP-001]

F 06/02/2015 Re-issued for Use C Bridgland J Gratton M Biddle

Document Number [14411-EP-001]

Version Date Description Author Checked Approved



Record of Revision It is certified that the amendments listed below have been incorporated in this copy of the publication

REV NO. SECTION DESCRIPTION OF CHANGES

Converted to an Empire Document with new document control number [EGO-HSE-RGPF-EP-001]

0 - Revision in line with DMP Guideline for the Development of Petroleum and Geothermal EPs in WA

0 2 Description of the Activity updated to reflect current infrastructure

0 2.8 Description of the Activity updated to include wellhead operations (WIAs)

0 4 Risk Assessment undertaken

0 5 Objectives, Standards and Measurement Criteria developed

0 10 Additional Consultation included

0 Appendix D Inclusion of Second Evaporation Pond - Basis of Design

1 7.5.1.2 Update Water Monitoring Bores information

1 Figure 12 Locations of three monitoring bores to be placed for both Evaporation ponds 1 & 2

1 Figure 13 Schematic diagram of monitoring bores, the type of monitoring bores to be installed, and their details

1 Appendix F Cardno WA PTY LTD on 21st July 2015 (Appendix F), Desktop Hydrogeological Study (Water Table) for RGPF

1 2.6.3 Note to say Evaporation Pond 2 not commissioned until regulatory approval. Table 21 Consultation updated.

1 4.1.11 PFW from RGPF only into RGPF Evaporation Ponds only

1 2.7 Load in treated PFW only – no hydrocarbons

1 Appendix E Approval Licence Number L8766/2013/1 from DER for Evaporation Pond

1 2.11 Timeframe and schedules for water monitoring bores installation

1 Table 16 WIA activities

1 Table 17 WIA activities

2 throughout Amendment of DMP to DMIR and DER to DWER where appropriate

2 2.6.3 3.1.6.3 4.1.3

4.1.11.1

Addition of statement “without DER approval”

2 10.4 Addition of reference to compliance report

3 Throughout Addition of key components from Bridging Environmental Plans; 3 Appendix G Addition of a chemical register that discloses all potential chemicals used during WIA

3 1 Update of subsidiary company Mineral Resources ltd, licence details L18,L19 and PL96

3 Throughout Regulator name changes (DMP to DMIRS, DER to DWER, DOW to DWER, DPAW to DBCA).

3 2.6.4 Evaporation pond 2 commissioning (detail updated from Pond commissioning EP EGO-RGPF-BD-EP-006, Rev 1) 3 2.6.6 Details on drilling camp updated

3 2.8 well operational activities updated to include, well testing, flaring, soap sticks, swabbing activities, velocity string and syphoning string activities, chemical squeeze (bullheading) and plug cementing. 3 2.8.6 well testing updated to include horizontal separator, flowback separator, flowback separator, flaring, chemical injection 3 2.8.9 Coil tubing well intervention activities (WIA) at RGPF updated information from EGO-RGPF-BD-EP-009, Rev 0)

Coil tubing well intervention activities (WIA) bridging EP

3 2.8.15 Well head compression station construction/commissioning and coil tubing activities: EGO-RGPF-BG-EP-007, Rev 0)) 3 2.8.16 Soap stick activities RG-1 – EGO-RGPF-BD-EP-010, Rev 0) information included into EP

3 2.8.18 Project timeframe, scope and equipment requirements (updated with WIA) timeframes and equipment and

bunding required. 3 4.14 Weed risk management and controls

3 4.1.14 chemical storage, handling and transport

3 4.1.17 Well head operations (WIA) controls and risk treatment options identified

3 5 Objectives, standards and measurement criteria updated to be SMART

3 7.3 Roles and responsibilities of personnel update

3 Table 23 2016 to 2017 consultation updated to include most recent communications relating to WIA stakeholder notification 4 2.8 &

Appendix G Inclusion of Chemical Disclosure for WIAs

4 2.6.3, 2.6.4, 4 & 4.1.10

Inclusion of:details on Humeceptor and Leach Drain

4 5 Improved Performance Standards as per DMIRS requirements

5 Appendix G Revised Chemical Disclosure

6 Throughout Update to include Red Gully North-01 and transition to C&M Operations

7 Throughout Amendments to address DMIRS queries on Rev 6



Table of Contents

1 Introduction .................................................................................................................................... 9 1.1 Nomination of Operator ......................................................................................................... 9 1.2 Environment Plan Objectives ................................................................................................ 10 1.3 Environment Plan Implementation ....................................................................................... 10 1.4 Environment Plan Revision ................................................................................................... 10 1.5 Other Documentation Details ............................................................................................... 10

2 Description of the Activity ............................................................................................................ 11 2.1 Location ................................................................................................................................. 11 2.2 Mapping ................................................................................................................................ 11 2.3 Topography ........................................................................................................................... 12 2.4 Hydrology .............................................................................................................................. 12 2.5 Facility Description ................................................................................................................ 24 2.6 Preservation .......................................................................................................................... 24 2.7 Infrastructure ........................................................................................................................ 24 2.8 C&M Activities ....................................................................................................................... 44 2.9 Maintenance of Cleared Areas.............................................................................................. 47 2.10 Decommissioning and Rehabilitation ................................................................................... 47 2.11 Timeframes and Schedules ................................................................................................... 48

3 Description of the Environment .................................................................................................... 49 3.1 Natural Environment............................................................................................................. 50 3.2 Cultural Heritage ................................................................................................................... 57 3.3 Socio-economic Environment ............................................................................................... 58

4 Environmental Risk Assessment and Management ...................................................................... 58 4.1 Risk Management and Justification of ALARP ...................................................................... 63 4.2 Risk Classification and Reporting Requirements .................................................................. 67

5 Objectives, Standards and Measurement Criteria ........................................................................ 68 6 Legislation and Other Requirements ............................................................................................ 77

6.1 Legislation ............................................................................................................................. 77 6.2 International Conventions and Agreements ......................................................................... 80 6.3 Standards .............................................................................................................................. 81 6.4 Other Requirements ............................................................................................................. 81

7 Implementation Strategy .............................................................................................................. 81 7.1 Systems, Practices and Procedures ....................................................................................... 82 7.2 Environment Policy ............................................................................................................... 83 7.3 Roles and Responsibilities of Personnel ............................................................................... 83 7.4 Training and Competencies .................................................................................................. 85 7.5 Monitoring, Auditing, Management of Non-Conformance, and Review ............................. 87 7.6 Record Keeping ..................................................................................................................... 90

8 Oil Spill Contingency Plan .............................................................................................................. 90 9 Reporting....................................................................................................................................... 91

9.1 Prestart and Cessation Notification ...................................................................................... 92 9.2 Activity Reporting (Annual Environmental Report) .............................................................. 92 9.3 Incident Reporting ................................................................................................................ 92 9.4 Emissions and Discharges Report ......................................................................................... 94 9.5 DWER Part V Licence AER ..................................................................................................... 96 9.6 CER NGER Reporting ............................................................................................................. 96

10 Consultation .................................................................................................................................. 96 10.1 Potential Stakeholders .......................................................................................................... 97 10.2 Ongoing Consultation ........................................................................................................... 97 10.3 Historical Consultation .......................................................................................................... 97



10.4 Recent Consultation .............................................................................................................. 97 Table 1: RGPF & RGN1 Documentation ................................................................................................ 11 Table 2: RGPF Project Coordinates ....................................................................................................... 11 Table 3: RGPF Project List of Figures ..................................................................................................... 12 Table 4: RGPF Project Coordinates ....................................................................................................... 24 Table 5: GGW1 / RG1 Wellhead Compound Infrastructure .................................................................. 25 Table 6: RGN1 Wellhead Compound Infrastructure ............................................................................. 26 Table 7: RGPF Flow Line Details ............................................................................................................ 34 Table 8: Flow Line Infrastructure .......................................................................................................... 34 Table 9: RGPF Infrastructure ................................................................................................................. 35 Table 10: Export Pipeline Details .......................................................................................................... 41 Table 11: Preservation Details .............................................................................................................. 41 Table 12: Red Gully Camps Details........................................................................................................ 42 Table 13: Red Gully Camps Preservation .............................................................................................. 42 Table 14: Laydown Areas Completion Criteria...................................................................................... 42 Table 15: C&M Activities ....................................................................................................................... 44 Table 16: RGPF Clearing Requirements ................................................................................................ 47 Table 17: Timeframes and Schedules ................................................................................................... 48 Table 18: Summary of Environmental Aspects ..................................................................................... 49 Table 19: Surface water features .......................................................................................................... 51 Table 20: Hydrological units associated with the project area ............................................................. 52 Table 21: Weed species known to occur in Chittering Shire ................................................................ 54 Table 22: Regionally Threatened and Priority Fauna Potentially Occurring in the Red Gully Area ...... 55 Table 23: Preservation Assessment Workshop..................................................................................... 58 Table 24: Issues not Requiring Further Assessment ............................................................................. 59 Table 25: Risk Assessment Table .......................................................................................................... 61 Table 26: Objectives, Standards and Measurement Criteria ................................................................ 68 Table 27: EP Act Part V Licence L8766/2013 Conditions ...................................................................... 78 Table 28: Empire Systems, Practices and Procedures .......................................................................... 82 Table 29: Roles and responsibilities of personnel ................................................................................ 84 Table 30: Training and Competencies ................................................................................................... 86 Table 31: Routine Site Inspections ........................................................................................................ 87 Table 32: Red Gully Groundwater Monitoring Bores ........................................................................... 88 Table 33: Auditing ................................................................................................................................. 89 Table 34: Environmental Reporting ...................................................................................................... 91 Table 35: Notifications .......................................................................................................................... 92 Table 36: Emissions and Discharges Reporting Parameters ................................................................. 95 Table 37: 2016 to February 2018 Consultation .................................................................................... 98 Figure 1: RGPF and associated infrastructure ....................................................................................... 13 Figure 2: RGN1 Well pad and Access Track ........................................................................................... 14 Figure 3: RGPF with reference to Petroleum Permits and Land Tenure............................................... 15 Figure 4: RGPF Environmental Sensitivities .......................................................................................... 16 Figure 5: RGN1 Environmental Sensitivities ......................................................................................... 17 Figure 6: Regional Environmental Sensitivities ..................................................................................... 18 Figure 7: RGPF Layout ........................................................................................................................... 19 Figure 8: GGW1 / RG1 Wellhead Compound Layout ............................................................................ 20 Figure 9: RGN1 and associated infrastructure ...................................................................................... 21 Figure 10: RGPF Camp Layout ............................................................................................................... 22 Figure 11: Site Photographs .................................................................................................................. 23



Figure 12: GGW1 Well Completion ....................................................................................................... 27 Figure 13: RG1 Well Completion ........................................................................................................... 28 Figure 14: RGN1 Well Completion ........................................................................................................ 29 Figure 15: GGW1 Wellhead Schematic ................................................................................................. 30 Figure 16: RG1 Wellhead Schematic ..................................................................................................... 31 Figure 17: RGN1 Wellhead Schematic (1) ............................................................................................. 32 Figure 18: RGN1 Wellhead Schematic (2) ............................................................................................. 33 Figure 19: Red Gully Laydown Areas ..................................................................................................... 43 Figure 20: GGW / RG1 and RGPF Groundwater Monitoring Bores ...................................................... 88 Figure 21: RGN1 Groundwater Monitoring Bores ................................................................................ 89

References

Document Code Title

Survey 2620, 1997 Red Gully Ethnographic Survey for Empire Oil and Gas NL (proponent), 01 Dec 1997

Golder, 2018 Report on installing and recording groundwater baseline levels in the Red Gully project area near Evaporation Pond 1 and 2. Prepared for MRL by Michael Bartlett, February 2018.

Quartermaine Consultants, 1997

Report On An Archaeological Survey For Aboriginal Sites In The Red Gully Project Area, Gingin. Prepared for Empire Oil & Gas NL by Sally McGann, December 1997

Quatermaine Consultants, 1999

Addendum To The Report On An Archaeological Survey For Aboriginal Sites In The Red Gully Project Area, Gingin. Prepared for Empire Oil & Gas, by Sally McGann. April 1999

Quatermaine Consultants, 2000

Addendum To The Report On An Archaeological Survey For Aboriginal Sites At The Tangletoe Project, Bullsbrook North Section. Prepared for Empire Oil & Gas, by Sally McGann. January 2000

Thompson, Mioduszewski, Nicol & Rouss 2011

Level 1 Reconnaissance Survey for Rare and Priority Flora Empire Oil & Gas 2012 Wannamal 3D Seismic Project Petroleum Exploration Permit EP389, Western Australia, 2011

Woodman Environmental Consulting, 2008

Flora, vegetation and Phytophthora cinnamomi assessment. Unpublished report for Empire Oil & Gas NL, 2008

Environmental Protection Authority, 1993

Red Book Status Report (1993), Report 15, Government of Western Australia, Perth

Environment Australia, 2000 Revision of the Interim Biogeographic Regionalisation for Australia (IBRA) and Development of Version 5.1 - Summary Report, Environment Australia, Canberra, ACT (website: http://www.deh.gov.au/parks/nrs/ibra/version5-summaryreport/index.html)

00/HSEQ/GEN/PC65 Upstream PS Corporate Induction Procedure

14411-PIMP-001 Pipeline Integrity Management Plan

24/HSEQ/GEN/PC07 Permit To Work (PTW) Procedure

http://www.deh.gov.au/parks/nrs/ibra/version5-summaryreport/index.html

http://www.deh.gov.au/parks/nrs/ibra/version5-summaryreport/index.html



Document Code Title

E001-DG-HS-001 RGPF Site Layout

E001-RP-GE-001 RGPF Basis of Design (BoD)

EGO-HSE-MAN-035 Empire Oil & Gas NL Health, Safety, Environment & Quality Management System Manual

EGO-HSE-FOR-010 Pre-operation Checklist

EGO-HSE-FOR-018 Stakeholder Contact Form

EGO-HSE-OSCP-003 Empire OSCP

EGO-HSE-PLA-005 Stakeholder Management Plan

EGO-HSE-PLA-008 Emergency Response Plan

EGO-HSE-PLA-009 Emergency Response Contact List

EGO-HSE-PRO-003 Weed Management Plan

EGO-HSE-PRO-012 Hazardous Material Procedure

EGO-HSE-PRO-036 Waste Management Procedure

EGO-HSE-PRO-037 Journey Management Procedure

EGO-HSE-PRO-038 Surveillance Sampling Program – Groundwater and Air Quality

EGO-HSE-REG-002 Weed Hygiene Inspection Register

EGO-HSE-REG-003 Waste Collection Register

EGO-HSE-RGPF-PR-001 Vegetation Clearing Procedure

EGO-POL-003 Empire Environment Policy

EGO-RGPF-OPS-013 Water Load-out Procedure

EGO-RGPF-OPS-014 Pipeline Integrity Management Plan

EGO-RGPF-OPS-015 Condensate Load-out Procedure

EGO-RGPF-OPS-016 Bund Liquid Removal Procedure

EGO-STA-300 Contractor Management Standard

EMP-PRO-02-2015 Pigging Procedure

RGPF-PLA-001 Red Gully Gas Field Preservation Plan

24COMHYPPRO013 RGPF Preservation of Facility Procedure

Bureau of Meteorology, 2017 Western Australia 2016 Climate Averages for Australian Sites – Gingin and Pearce RAAF: www.bom.gov.au/climate

Red Gully Condensate Safety Data Sheet (SDS)

L8766/2013/1 EP Act Part V Licence Red Gully Processing Plant

E001-DG-HS-001 Red Gully Fire and Safety Layout

EGO-HSE-OSCP-003 Empire Oil Spill Contingency Plan

http://www.bom.gov.au/climate



Term Definitions and Abbreviations

Abbreviation Definition

AER Annual Environmental Report

AIEA Annual Internal Environmental Audit

APPEA Australian Petroleum Production and Exploration Association

ALARP As Low as Reasonably Practicable

ASAP As Soon as Possible

ASL Above Sea Level

BoD Basis of Design

CBTA Competency Based Training Assessment

CER Clean Energy Regulator

CMMS Maintenance System

DBCA Department of Biodiversity conservation and Attractions (previously DPaW)

DBNGP Dampier to Bunbury Natural Gas Pipeline

DER Department of Environment Regulation

DG Dangerous Goods

DMIRS Department of Mines, Industry Regulation and Safety (previously Department of Mines and Petroleum)

DWER Department of Water and Environment Regulation (formerly DER)

E&Ds Emissions and Discharges

EARS Environmental Assessment and Regulatory System

EGC Export Gas Compressor

Empire Empire Oil & Gas NL

EP Environment Plan

EP Act Environmental Protection Act 1986

EPA Environmental Protection Authority

EPBC Environment Biodiversity Conservation Act 1999

ESA Environmentally Sensitive Area

FGC Flash Gas Compressor

GDE Groundwater Dependent Ecosystem

GEA Gas Engine Alternator

GGW1 Gingin West-1 Well

HSEQ Health, Safety, Environment and Quality

JHA Job Hazard Analysis



Abbreviation Definition

LTS Low Temperature Separator

MNES Matters of National Environmental Significance

MOC Management of Change

MyOSH Empire HSEQ Database

NATA National Association of Testing Authorities

NGER National Greenhouse Energy Reporting Act 2007

NPI National Pollutant Inventory

OSCP Oil Spill Contingency Plan

PEB Petroleum Environment Branch

PFW Produced Formation Water

PGER Petroleum Geothermal Energy Resources Act 1967

PIMP Pipeline Integrity Management Plan

PL96 RGPF Export Pipeline

PP Petroleum Pipelines

RG1 Red Gully-1 Well

RGN1 Red Gully North-1 Well

RGPF Red Gully Gas Pipeline and Processing Facility

SDS Safety Data Sheet

SWL Standing Water Level

WIA Well Intervention Activities

1 Introduction

Empire Oil Company (WA) Limited (Empire or the Company) is an Australian oil and gas company with onshore exploration assets in the Perth Basin of Western Australia. The Company is incorporated in New Zealand, and is a registered foreign company in Australia, with ARBN 009 475 423. The Company is now a wholly owned subsidiary of Mineral Resources Limited (CAN 118 549 910) (Mineral Resources).

1.1 Nomination of Operator

Empire have permits in the Perth Basin including Production Licences L18 and L19, Petroleum Pipelines Licence PL96 and Exploration Permit EP389. The infrastructure within these permits includes:

Red Gully-1 (RG1), Gingin West-1 (GGW1) Production Wells

Red Gully Gas Pipeline and Processing Facility (RGPF) and associated infrastructure

Export pipeline associated with the RGPF

Red Gully North-1 (RGN1) Exploration Well



The permits are owned and operated by Empire Oil Company (WA) Limited under this Red Gully Care and Maintenance (C&M) Environment Plan [EGO-HSE-RGPF-EP-001] (this EP). A written notification of this nomination for all the permits listed above was provided to the Department of Mines, Industry Regulation and Safety (DMIRS) Petroleum Environment Branch (PEB) in an application dated 30/11/2017 (Appendix A).

1.2 Environment Plan Objectives

Due to recent well performance issues, RGPF is not in production and Empire will manage the infrastructure in the permits above under C&M.

This Environment Plan (EP) has been written to meet the following objectives:

Describe the key aspects of C&M at Red Gully

Detail specific information on the environmental sensitivities of the receiving environment

Identify potential environmental impacts of C&M at Red Gully

Describe the control measures that will be implemented to minimise the environmental impact of Red Gully C&M and ensure that the environmental objectives are achieved

Evaluate the environmental hazards and consequences associated with Red Gully C&M, assess the environmental risk levels and develop management measures to ensure risks are kept to an acceptable level

To document this information

For implementation by Mineral Resources employees and contractors

For use by regulatory authorities in the environmental assessment and approval process

This EP has been prepared in accordance with the DMIRS ‘Guideline for the Development of Petroleum and Geothermal Environment Plans in Western Australia, November 2016’.

1.3 Environment Plan Implementation

Empire are the custodian of this EP and has overall responsibility for its implementation, compliance and revision.

1.4 Environment Plan Revision

This EP will be revised when:

The EP has been approved for a period of five years

A new activity is proposed which is not provided for in the EP

Any significant modification of an activity is proposed to commence which is not provided for in the EP

There is a change in the instrument holder or operator of the activity

New or increased environmental risks or impacts associated with the activity have been identified

Empire makes material changes to environmental management systems, processes, mitigation measures, environmental performance objectives, standards, measurement criteria

Where acceptable to DMIRS, a bridging document may be developed for an activity following consultation with the DMIRS

1.5 Other Documentation Details

Details of other documentation associated with the RGPF project are outlined in the documents listed in Table 1.



Table 1: RGPF & RGN1 Documentation

Document Number Name Purpose Status

EGO-HSE-OSCP-RGPF-003

Oil Spill Contingency Plan

Provide guidance on the preparation and response to a spill incident

Approved 25/7/2017

EGO-HSE-RGN1-EP-002

Management of Red Gully North-1 Environment Plan

Documentation of environmental management at RGN-1 (site under care and maintenance)

Archived on approval of this document

EGO-HSE-OSCP-RGN1-003

Oil Spill Contingency Plan RGN-1

Provide guidance on the preparation and response to a spill incident at RGN-1

Approved 11/9/2017

2 Description of the Activity

2.1 Location

Red Gully comprises of:

RG1 and GGW1 wells within Production Licences L18 and L19

Flow line from RG1/GGW1 to RGPF

RGPF within Pipeline Licence PL96

Red Gully Gas Pipeline (Export Pipeline) licensed under PL96 which delivers processed gas into the export pipeline connecting to the Dampier Bunbury Natural Gas Pipeline (DBNGP)

RGN1 Exploration well within Exploration Permit EP389

The RGPF is located approximately 17km north of the Gingin town site (Figure 3). Primary access to the site is through Wannamal Road West and Brand Highway. The coordinates for Red Gully infrastructure are presented in Table 2.

Table 2: RGPF Project Coordinates

Location Easting Northing

RGPF 388 565 mE 6 549 918 mN

PL96 Connection to DBNGP 386 018 mE 6 548 749 mN

RG1 388 162 mE 6 549 802 mN

GGW1 388 166 mE 6 549 780 mN

RGN1 388 053 mE 6 553 753 mN

2.2 Mapping

Table 3 presents the mapping requirements for the Red Gully Production and Operations project EP.



Table 3: RGPF Project List of Figures

Mapping Information Description

Aerial Images Figure 1 RGPF and associated infrastructure

Figure 2 RGN1 Well pad and Access Track

Permit Boundaries and Cadastral Information Figure 3 Red Gully infrastructure (RGPF and RGN1) with reference to Petroleum Permits and Land Tenure

Sensitive Receptors Figure 4 RGPF Environmental Sensitivities

Figure 5 RGN1 Environmental Sensitivities

Figure 6 Reginal Environmental Sensitivities

RGPF Layout Figure 7 RGPF Site Layout

Red Gully-1 and Gingin West-1 Wellhead Layout Figure 8 Wellhead Layout

RGN1 Wellhead Layout Figure 9

Camp Layout Figure 10 Camp Layout

Photographs Figure 11 Wellhead Compound, RGPF and Camp

2.3 Topography

The RGPF is 176 mASL and RGN1 is 198 mASL.

2.4 Hydrology

The hydrology of the area is described in section 3.



Figure 1: RGPF and associated infrastructure



Figure 2: RGN1 Well pad and Access Track



Figure 3: RGPF with reference to Petroleum Permits and Land Tenure

PL96


Document Number EGO-HSE-RGN1-EP-002 of 124

Figure 4: RGPF Environmental Sensitivities



Figure 5: RGN1 Environmental Sensitivities


Document Number EGO-HSE-RGN1-EP-002

of 124

Figure 6: Regional Environmental Sensitivities



Figure 7: RGPF Layout



Figure 8: GGW1 / RG1 Wellhead Compound Layout



Figure 9: RGN1 and associated infrastructure



Figure 10: RGPF Camp Layout



Figure 11: Site Photographs

Top Left: RGPF (Section 2.7.3), Top Right: Wellhead Compound with Turkey’s Nest in background (Section 2.7.1),

Bottom Right: RGPF Camp with RGPF in background (Section 2.7.5)



2.5 Facility Description

The scope of this EP is for the C&M of infrastructure associated with Red Gully and includes the following infrastructure:

GGW1 and RG1 wells drilled 2009 and 2011 respectively (L18)

Flow line from GGW1/RG1 to RGPF

RGPF (PL96)

Export Pipeline (PL96)

Camp

RGN1 well drilled 2015

Section 3.6 describes this infrastructure in further detail.

All Red Gully C&M activities are within existing disturbed areas. Access is via Brand Highway and Wannamal Road.

2.6 Preservation

A workshop was undertaken by personnel from operations, safety, process, maintenance, engineering and wells to determine the requirements for preserving infrastructure associated with Red Gully prior to the commencement of C&M activities [24COMHYPPRO013]. The preservation scope is intended to preserve the plant in a status to carry out care and maintenance activities with minimum maintenance requirements without sacrificing safety and environmental condition. The period for preservation will be a period of up to 5 years.

Preservation includes:

Evacuating liquids from vessels and piping

Removing gas and remaining hydrocarbons from vessels and equipment

Purging facility from wellhead to export with Nitrogen

Isolating potential pressure sources from facility

Blanketing remaining facility with Nitrogen

Machine preservation to reduce maintenance while allowing easy start-up when required

The facility will be un-manned with gates locked. Competent personnel will be nominated and conduct checks on a monthly basis.

Equipment removed from the system required for restart of the plant will be preserved in the Red Gully workshop in preparation for future re-installation.

2.7 Infrastructure

2.7.1 Wellhead Compounds

The wells under C&M are included in Table 4. Schematics have been included of the well completion for GGW1 (Figure 12), RG1 (Figure 13) and RGN1 (Figure 14). Schematics have been included of the wellheads for GGW1 (Figure 15), RG1 (Figure 16) and RGN1 (Figure 17 & 18).

Table 4: RGPF Project Coordinates

Well Location Easting Northing Depth

GGW1 L18

(single well pad)

388 166 mE 6 549 780 mN 3,870 m

RG1 388 162 mE 6 549 802 mN 4,000 m

RGN1 EP389 388 565 mE 6 549 918 mN 3,859 m



2.7.1.1 GGW1 / RG1 Wellhead Compound

The infrastructure located at the GGW1 / RG1 wellhead compound is included in Table 5. Figure 12 and 13 include the well diagrams and Figure 15 and 16 present the wellhead diagrams. The wellhead compound is graded and managed to control weeds encroaching on the well pad.

Table 5: GGW1 / RG1 Wellhead Compound Infrastructure

Infrastructure Description C&M Status Preservation Activities

GGW1 Wellhead RGPF Well Live Pressure taken

Shut valves

Integrity test

Valve handwheels chained

RG1 Wellhead RGPF Well Live Pressure taken

Shut valves

Integrity test


Pipework upstream of positive isolation

Isolation Method Shut-in Install flange

Graded gravel pad In place Nil

Wellhead Fencing Barrier around wellheads In place Nil

Turkey’s Nest GGW1/RG1 Water Storage

In place Nil

Storage and Laydown Area

Area on GGW1/RG1 well pad

In use Assess stored materials and dispose of superfluous items

Chemical Injection Area Self-bunded containers and injection tubing

Shut-in Remove well head pump

Chemical removed from site

Steel containers stored in workshop

Instrument loop power and instrument air

Shut-in Shut-in

Wellsite Container Control room for proposed compressor

Locked Nil

Groundwater Bores Abstraction Water Bore (Magpie Bore) - Yaragadee Aquifer (360m)

Locked Shut-in

Three monitoring bores surrounding the GGW1 / RG1 well pad

Locked Nil



There are three monitoring bores located at the GGW1 / RG1 wellhead compound (details are included in Section 7.5.1.2).

2.7.1.2 RGN1 Wellhead Compound

The RGN1 well is located approximately 24 km north of the Gingin town site (Figure 3). The well diagram is included as Figure 14 and the wellhead diagram is included as Figure 17 and 18. Primary access to the site is via Brand Highway, Wannamal Road West and a 5.4 km upgraded farm access track. The graded compound is approximately 2 ha. The infrastructure located at RGN1 is included in Table 6. There is one monitoring bore located at the RGN1 wellhead compound (details are included in Section 7.5.1.2).

Table 6: RGN1 Wellhead Compound Infrastructure


RGN1 Wellhead Fenced wellhead with surrounding 300 mm berm and fauna egress

Suspended Suspend well (valves closed)

Integrity test


Cuttings Sump Decommissioned In place Remediation of sump underway

Turkey’s Nest Lined (0.5mm LLDPE (Linear Low Density Poly Ethylene)) and fenced with fauna egress

In place Liner removed

Flare pit Horizontal Flare pit In place Remediated

Groundwater Bores Groundwater Abstraction Bore

Locked Nil

Monitoring Bore Downstream of RGN1 well pad

Locked Nil



Figure 12: GGW1 Well Completion



Figure 13: RG1 Well Completion



Figure 14: RGN1 Well Completion

Red Gully Gas C&M Environment Plan


Figure 15: GGW1 Wellhead Schematic



Figure 16: RG1 Wellhead Schematic



Figure 17: RGN1 Wellhead Schematic (1)



Figure 18: RGN1 Wellhead Schematic (2)

2.7.2 Flow Lines

An above-ground carbon steel flow line, 24-volt instrument loop power line and an instrument airline connect the wellheads to RGPF. The flow line was constructed in 2013 in accordance with BS 31.3. There are no pigging facilities on the flow line. Flow line details are presented in Table 7.



Table 7: RGPF Flow Line Details

Flow Line Specification KP KP Location

RGPF Flow Line DN100, Sched XXS, Class #1500S

0 flare

0.2 ROW connects with export pipeline

0.75 RGPF

The Red Gully flow line and preservation activities are presented in Table 8.

Table 8: Flow Line Infrastructure


RGPF Flow Line Connection between GGW1 / RG1 and RGPF

Shut-in Up to 35 kPag Nitrogen Gas Blanket

2.7.3 RGPF

The facilities required to process the GGW1 and RG1 fluid are gas treatment (water and hydrocarbon dewpoint conditioning), gas export compression, condensate stabilisation and produced water treatment.

The RGPF site is contained within a core area of approximately 5 ha (300m x 350m) (layout Figure 7) and includes the structures and equipment presented in Table 9.

There are three monitoring bores around the RGPF evaporation ponds (details are included in Section 7.5.1.2).



Table 9: RGPF Infrastructure


Vessels Wellhead Separator / Slug catcher - Captures received liquids, controls slugs and separates bulk liquids from wet gas (7 kL)

Preserved Drain Vessel

Low Temperature Separator (LTS, V-1201) - conditions gas to meet transmission quality (concrete bunded) (376 L)

Nitrogen Purge

Condensate Knock Out Drum (V-0302) - separate bulk gas generated by heating (468 L)

Up to 35 kPag Nitrogen Gas Blanket

Condensate Flash Vessel (V-0301) - three phase separator (3.2 kL)

Free Water Knock out Drum (FWKOD, V-0110) - Produced Water Treatment - separates water from condensate (concrete bunded) (154 L)

Wet Gas Cooler (E-0101) cools gas prior to entry into the gas / gas exchanger (221 L) Preserved Up to 35 kPag Nitrogen Gas Blanket

Gas/Gas Exchanger (E-1201) Further cooling of gas (tube 320 L / shell 830 L) Preserved Drain liquids


Export gas compressor (EGC)(A-1001) Generator (GEA) (A-5001)

EGC to compress ‘sales gas’ to export pressure (bunded) (1214 L)

GEA uses ‘sales gas’ for power generation

EGC within enclosure to reduce noise level equipped with sufficient ventilation while operating

Preserved Discharge liquid in the system

Nitrogen purge

Spray vapour corrosion inhibitor (VCI) in the gas engine chamber and compressor vessel and bottles

Gas engine shaft rotated 360 degrees then 90 degrees monthly

Condensate Flash Gas Compressor (FGC) (444 L) (A-1101)

Within enclosure to reduce noise level equipped with sufficient ventilation while operating

Preserved Isolated from plant

Vapour corrosion inhibitor applied

Filters ‘sales gas’ (351 L) Preserved Drain liquids




Export Gas Filter Coalescer (V-1301)


Export Gas Metering and Gas Chromatograph

At RGPF Preserved Instrument isolated

Power off


Fuel Gas Coalescer (37 L) Preserved Drain liquids


Condensate Heater (H-0201) Heats condensate so that it will meet sales quality specification (180 L)

Preserved Up to 35 kPag Nitrogen Gas Blanket

Rundown Pumps Boost stabilised condensate pressure (concrete bunded) Preserved Drain liquids


Condensate Rundown System Cools condensate to below maximum condensate tank temperature

Preserved Up to 35 kPag Nitrogen Gas Blanket

Water Rundown System Cools PFW Preserved Up to 35 kPag Nitrogen Gas Blanket

Condensate Storage Tanks (T-0501A/B)

Two x 150 kL bunded horizontal storage tanks Shut-in Condensate taken to BP Refinery

Remaining liquids taken offsite for disposal

Tanks left to breathe

Produced water storage tank (T-2001)

One x 40 kL bunded horizontal storage tank Shut-in PFW drained to Evaporation Pond

Top layer liquids drained and taken offsite for disposal

Tank left to breathe

Condensate Loading Skid (A-0601) Loading equipment Preserved All liquid hydrocarbons removed from tanks, lines, and pumps.





Loading Bay Stabilised Condensate Loading bay allows liquids (where contaminated) to drain into a “Humeceptor” when drain valve is opened

Includes Load Out Area Shed (10ft Container)

In place Close valve

Humeceptor Underground system that utilises hydrodynamic and gravitational separation to efficiently remove total solids and entrained hydrocarbons from runoff. There will be no contaminated liquids on the loadout bay during C&M. The uncontaminated stormwater collected on the bay will be directed to the Humeceptor (prior to offsite discharge) during monthly inspections.

Inlet valve closed Remove outlet pipe to provide sample point

Close loading bay outlet valve

Uncover leach drain

Sample soil and remediate if required

Vent knock out drum and vent header

Atmospheric vent (1,650 L) In place Connect knock-out drum to atmosphere

No action required on vent header

Pipework containing hydrocarbon gas

Around RGPF Preserved Nitrogen Purge


Pipework containing liquids Around RGPF Preserved Drain into system

Collect residual liquid for offsite disposal

Nitrogen purge


Evaporation Pond 1 HDPE lined 50m x 50m evaporation pond installed with fauna egress matting and ramps

In place When empty, assess soil in pond

Test liner integrity

Assess requirement to ensure stabilisation of the base of pond to prevent liner from lifting




Evaporation Pond 2 HDPE lined 105m x 118m (external bund edge to edge) evaporation pond. The pond bottom is lined with 300mm of sieved sandy loam soil with a construction equipment access ramp for fauna egress. A chain mail fence surrounds the perimeter of this pond for additional protection of fauna.

In place Fenced and locked

Electric pumps Around the plant for chemical injection or liquid movement In place Flush injection line with water

Electrically isolate

Pig Launcher Export gas pipeline pig launching facility Preserved Up to 35 kPag Nitrogen Gas Blanket

Air compressor package Air compressor (A-3001A/B) in shed - compressed dry air for SDVs, control valves and pneumatic pumps

Shut-in Maintain with dry air

Air compressor (A-3001C) behind workshop – back-up to be utilised for C&M where required now

In place Maintain with dry air

Chemical operational and storage area

o Methanol injection (common bund) (currently injected) o Corrosion inhibitor injection (common bund) (currently

injected) o Hydrogen sulphide scavenger injection (potential if

required) o Biocide dosing (potential if required) o Emulsifier and demulsifier treatment (common bund) o Engine oil and coolant o Diesel

Chemical shed is a bunded 2m x 3m adjacent to the workshop to store all portable chemicals (lubes oils, diesel, paints etc.)

- All bulk chemicals will be removed from site

Large containers

Injection pumps and lines past SDVs flushed with freshwater

Pneumatic pumps from well area removed and stored in warehouse.

- Small volume chemicals in chemical shed and chemical cabinet

Diesel storage tank Vehicle refuelling Isolated Diesel storage tank emptied

Refuelling hose removed

Site drainage o Drains from process permanent bunds (designed for 1 in 100-year storm) drain to a low point with locked valve

In place Ensure all bund valves closed

Fire management equipment Fire trailer Out of service Store in Warehouse




Portable fire extinguishers In place Maintain in service at least one foam fire extinguisher in workshop

In storage Remove foam extinguishers into warehouse and tag out of service

Main Control Centre A secure transportable style service building that contains

Communications and control equipment

Power distribution and UPS equipment

Data and safety monitoring system

Small office

In place Locked

Production Laboratory In place Locked

Workshop Workshop for basic maintenance and the storage of a 180 L spill kit containing

Spare booms

Absorbent pads

Plastic bags

In place Workshop locked and spill kit maintained in service

Warehouse Warehouse provides for the bulk of critical spares to be stored onsite including PPE supplies:

2 x long handle shovels

2 x pairs chemical resistant boots

2 x pairs chemical resistant gloves

2 x pairs chemical resistant goggles

Dust masks

Heavy duty plastic garbage bags

In place Warehouse locked and spill kit maintained in service

40ft Storage Container 40-foot standard sea container converted to allow additional storage of critical spares onsite

In place Locked

Ablutions Block In place Building locked




2m x 3.6m x 3m building with black water drainage to a septic sewage system with leach drain

Septic tank pumped out

Laydown and storage area approximately 0.36ha (60m x 60m) with designated access track

In place Waste removed

Rehabilitated if no longer required

Rainwater tank Rain is harvested from the Workshop & Storage Shed roof for workshop drinking/utility water and gas plant Ablutions Block utility water.

In place Nil

Back-up power supply connection to Western Power electricity grid In place Nil

Fire breaks Site ring road / fire break to lay down and storage area In place As per maintenance schedule



2.7.4 Export Pipeline (PL96)

The export pipeline transfers gas from RGPF to the Dampier to Bunbury Natural Gas Pipeline (DBNGP) to natural gas customers in Perth. The pipeline is designed in accordance with AS2885.1. A pig receiver is located adjacent to the DBNGP tie-in point. Export pipeline details are presented in Table 10.

Table 10: Export Pipeline Details

Pipeline Specification KP KP Location

Export Pipeline DN100, ASME Class 600 0 RGPF

1.67 Property Boundary /Track

2.25 Track

3.03 DBNGP

Table 11 presents the infrastructure associated with PL96 and summarises the preservation activities outlined in the Preservation Plan.

Table 11: Preservation Details


Pipeline Upstream of isolation at RGPF

Shut-in Up to 35 kPag Nitrogen Gas Blanket

Pipeline Downstream of isolation at RGPF

Shut-in Isolated (contains process gas)

Pig Receiver Export gas pipeline pig receiving facility

In place Up to 35 kPag Nitrogen Gas Blanket

Connection to DBNGP Isolated Double block and bleed manifold

Installation of blind flange

Remove pipework in between designated flanges

2.7.5 RGPF Camp

There are two camps associated with Red Gully. Details on the camps are included in Table 12. Preservation activities are listed in Table 13.



Table 12: Red Gully Camps Details

Item Accomodation Camp Temporary Drilling Camp

Area 0.16ha on previously cleared land 80m x 80m

Original Use RGPF construction and commissioning temporary accommodation camp

Red Gully Drilling Operations from 2009

Maximum # Personnel 16 Nil

Septic Shire of Gingin approved septic system with leach drain

3 x concrete septic tanks have been pumped out and the installation removed and disposed offsite

Water supply Rainwater harvesting Nil

Camp Design Buildings connected by concrete walkways

Vacant gravel pad used as a laydown area

Table 13: Red Gully Camps Preservation


Buildings Doors and Windows In place Lock

Air conditioning units Installed in buildings In place Nil

Accommodation camp septic

Septic tank In place Septic tank pumped out

Water Tanks In place Nil

2.7.6 Laydown Areas

Equipment in laydown areas (Figure 19) of no future use will be taken offsite for recycling or disposal at a licenced waste facility. Soil from unused laydown areas will be sampled to confirm that there is no contamination before being left available for future use.

Rehabilitation of laydown areas will be managed in accordance with this EP. Rehabilitation will involve:

Removal of sheeting materials

Reinstating landform

Inspect monthly for weeds, erosion, waste, third party access

Weed control line with completion criteria requirements

Assess annually until completion criteria are achieved

Implement remedial measures identified during inspection and assessment activities

Completion criteria are presented in Table 14.

Table 14: Laydown Areas Completion Criteria

Aspect Objective Criteria Method

Infrastructure To ensure that all visual disturbances are removed

There should be no permanent markers left

on the laydown area

Visual inspection of laydown area



Aspect Objective Criteria Method

Landform

To reinstate the land to provide suitable conditions for future land use

Natural contours should be re-instated to pre-

disturbance conditions

Visual inspection of laydown area

There should be no active erosion rills

greater than 10m x 0.3m

Physical measurement of any points of erosion

Weeds

To ensure that laydown areas do not create a source of weeds

The foliage cover of declared and

environmental weeds on laydown areas should be

similar to surrounding farmland

Visual assessment of weed species presence and percentage cover

Monitoring To ensure that the land owner endorses the laydown areas rehabilitation outcome

Laydown areas are returned to pre-

disturbance conditions

Documentation of landowner acceptance of laydown area

Figure 19: Red Gully Laydown Areas



2.8 C&M Activities

The listing of C&M activities for Red Gully are included in Table 15.

Table 15: C&M Activities

Activity Site Frequency Detail

Routine Inspections GGW1 / RG1, Flow Line, RGPF, PL96, RGN1

Monthly Items on monthly checklist, including:

Visual Inspection of all equipment and infrastructure for interference or damage including access tracks

Assessment of environmental aspects including weeds, firebreaks, erosion, leakage and other observations

Inspection of piping for leakages or signs of damage, pitting, coating deterioration, deformation, bulging etc

Gauge readings,

Verification of positive isolation from reservoir well

Compressor and equipment inspection for any signs of rust, damage etc

Assessment for the requirement to undertake dust suppression

Check tamper tag / contents of spill kit in the workshop to ensure it is stocked with serviceable booms, absorbent pads and plastic bags

Check that the PPE in the warehouse is available and serviceable

RGPF Monthly Pressurisation of blanket gas, if required

Housekeeping GGW1 / RG1, Flow Line, RGPF, PL96, RGN1, Access Tracks

As required Housekeeping

Remedial measures required as identified during routine inspections and maintenance schedule within 2 months of observation (or by work order due date)

Bund Management

GGW1 / RG1, RGPF, RGN1 As required Weed Control

Gas Engine Preservation EGC, FGC Monthly Gas engine shaft rotated 360 degrees then 90 degrees




Annually Re-preserve EGC and FGC

Pest Control RGPF, Camp Monthly As required

Pneumatic System RGPF SDVs, LCVs etc As needed Run up pressure in air compressor package to cycle pneumatic control equipment

EEHA Inspection Electrical Equipment in Hazardous Areas

4-yearly (2020)

Cathodic Protection Survey PL96 Annually (February) Pipeline cathodic protection system effectiveness inspection

Direct current voltage gradient (DCVG) survey

PL96 2-yearly (February 2020) Check coating quality

Electrical Equipment Certification

RGPF Office Annually (November) Test and tag for in-use office equipment

Nil Tag “out of service” equipment

Wellhead Inspection and Maintenance

GGW1, RG1, RGN1 Annually Tree Valve Maintenance (e.g. greasing valves, pressure monitoring)

Western Power Meter Reading

RGPF As required Provide grid electricity meter reading to Western Power

Firebreak Maintenance GGW1 / RG1, RGPF, RGN1, Camp

Annually (by 7th November)

Ensure firebreaks around facility and well pads are maintained

ROW Patrol

Flowline, PL96 After heavy rainfall Checks undertaken for washouts, ground settlement and third-party activity

Monthly Observe above ground sections of pipeline

Quarterly Drive ROW

As required Rectify issues where issues are identified

Annually Walk ROW to ensure right of way is maintained in accordance with Pipeline Integrity Management Plan (PIMP)




Fire extinguisher service GGW1 / RG1, RGPF 6-Monthly (January & July)

Pressure Test where extinguisher is in service

Fire detection and alarm system check

RGPF 6-monthly (February & August)

Groundwater Monitoring Groundwater monitoring bores at GGW1 / RG1, RGN1 and RGPF

Quarterly with annual frequency assessment

Groundwater monitoring as per MRL Groundwater Surveillance Program of:

3 x monitoring bores at GGW1 / RG1

1 x monitoring bore at RGN1

3 x monitoring bores around RGPF Evaporation Ponds

Discharge Water Monitoring

Monitoring of Humeceptor outlet sample point

Monthly Water sample of discharge water for hydrocarbons to confirm uncontaminated liquids are discharged from the Humeceptor

Visual inspection under Humeceptor lid

Quarterly Check soil conditions

Rectification Works flare pit, turkey’s nest, laydown area

Where required Soil sampling, material removal and disposal, waste disposal, landform adjustment and where appropriate top soil reinstatement

Annual Internal Environmental Auditing

GGW1 / RG1, Flow Line, RGPF, PL96, RGN1

Annual Audit against the performance objectives, standards and measurement criteria in this EP (Section 5)

Environmental Reporting DWER - RGPF Annual Submission of an AACR and AER to DWER

DMIRS – GGW1 / RG1, Flow Line, RGPF, PL96, RGN1

Monthly (Recordable) Report documenting incidents that breach an objective or standard in this EP (Section 9.3.2)

Quarterly (E&Ds) Report documenting Emissions and Discharges associated with C&M activities in accordance with this EP (Section 9.4)

Annual (AER) Report documenting the items listed in Section 9.2 of this EP



2.9 Maintenance of Cleared Areas

Maintenance of cleared areas for firebreaks, operational compounds, pipeline easements, access tracks and laydown areas will be conducted in accordance with the legislative instruments listed in Table 16. An Environmental Protection Act 1986 Clearing (Purpose) Permit will be required for any other clearing activities

Table 16: RGPF Clearing Requirements

Location Area Legislative Driver

RGPF general area including firebreaks, compounds, laydown and flow line and pipeline easements in all other areas

<1 ha/annum Regulation 5 of the Environmental Protection (Clearing of Native Vegetation) Regulations 2004: Exemption 15 (clearing to maintain existing cleared areas around infrastructure etc.)

2.10 Decommissioning and Rehabilitation

A decommissioning Environment Plan shall be submitted to the relevant decision-making authority for any decommissioning and rehabilitation associated with the RGPF at least 3 months prior to the planned decommissioning and rehabilitation activities. The removal of flare pits, laydown areas and Turkey’s Nests will be managed in accordance with this EP to ensure the sites are left in a secure manageable state. Removal activities will involve:

Removal of foreign materials including muds and liners

Validation soil sampling

(If required) removal of any contaminated material identified

Filling all excavations in consultation with the landowner

Monitoring sites during monthly inspections (Section 7.5.1.1)

RGPF has a design life of fifteen years or a longer period if determined by engineering review. Empire Oil will retire the pipeline and production facility in compliance with all applicable statutory and regulatory obligations, in a safe and environmentally acceptable way. The decontamination process will be phased as follows:

Pig, flush and clean PL96 to remove contents and contaminants and displace fluids back to the downstream process

Where contaminated, decontaminate equipment by flushing and internal clean out. Waste cleaning fluids to be disposed using existing downstream processing facilities and evaporation pond. Any hazardous material will be identified and treated separately as required.

The demolition process will commence after decommissioning and decontamination as follows;

Conduct well plug and abandonment (by others)

Remove flow lines. If pipeline is supported, supports and footings shall be removed

Export gas pipeline to be capped below ground level and left in place after flushing back to the plant

Remove headers / manifolds near facilities

Dismantle interconnecting piping between equipment within the facilities

Where possible, equipment will be removed and transported intact. Otherwise, equipment will be cut into a transportable size prior to removal

Transportable buildings where possible will be transported intact

After cleanout of bunded areas and removal of foundations, it is envisaged that there will be sufficient existing soil in the perimeter earth bund to refill the open pits and level to match the existing ground contours without the requirement of import fill. The soil area within these bunds will be checked for any



contamination and appropriate steps taken to treat or dispose of the contaminated soil consistent with all regulations and requirements

Confirmation samples will be taken below hydrocarbon liquid bunds to ensure that all affected soil has been removed

Landform reinstatement will be undertaken

All contaminated soil found on the site will be collected and transported to a suitable licenced waste management facility.

The objective of the reinstatement scope is to achieve a safe and sustainable landform and an environment that is visually compatible with its surrounds. Reinstatement work is conducted after decommissioning and demolition stage of the site.

Typical land reinstatement work at the site should include, but not limited to the following activities:

1. Clean-up of entire site and around the site, to confirm that:

a) All litter from demolition / decommissioning stage has been completely removed, such as concrete pavement rubble, metal debris, electrical cables, tools, etc.

b) Any contamination has been removed from site for treatment or disposal, such as contaminated soil, leak or spills.

2. Profiling site to match surrounding landscape. This includes excavation and reusing noncontaminated fill to backfill voids.

3. Ensuring any demolition waste or dirt transferred to the Wannamal Road West is removed and the road is cleaned.

2.11 Timeframes and Schedules

Table 17 outlines the current timeline for RGPF & RGN1.

Table 17: Timeframes and Schedules

Activity Timeframe Duration Hours of Operation

Red Gully Production and Operations

Commenced 2013 2018 24 hrs/day (manned 12 hrs/day)

Loading Activities (Condensate)

2015 2018 Daylight hours only

Produced Water Handling Upgrade

March 2017 Complete -

Evaporation Pond 2 Construction

2017 Complete -

Installation of three Water Monitoring Bores for Evaporation Ponds 1 & 2 at RGPF

28th February 2018 1 month Daylight hours only

Well Head Compression Project (civil and commissioning)

Commenced 2017 2 Months Daylight hours only

Well Intervention Activities

On regulatory approval

[2017]

15 Days 24 hrs/day

C&M Activities 2018 5 years Daylight hours



Activity Timeframe Duration Hours of Operation

Removal of contents RGN1 Cuttings Sump

March & April 2018 15 Days Daylight Hours

Laydown area rehabilitation monitoring

Up to achievement of completion criteria

- Daylight Hours

3 Description of the Environment

A description of the environment in the Red Gully area is included in Section 3. Red Gully relative to potential environmental receptors is presented in Figure 4, 5 and 6. A summary of the environmental aspects in relation to Red Gully C&M activities is included in Table 18.

Table 18: Summary of Environmental Aspects

Aspect RGPF RGN1

Climate Mediterranean climate characterised by seasonal patterns of hot, dry summers and mild, wet winters

Soils Red and yellow earthy sands over calcareous rocks and siliceous rocks

Surface water Livestock sand seep (430m north)

Beermullah Lake (1.8 km southwest)

Red Gully Creek South (2.6km north)

Red Gully Creek South (300m west)

Red Gully Farm Soak (1km south)

New Springs Seep (3.5km south)

Groundwater Yaragadee Aquifer is approx. 300m below surface with superficial aquifers at approx. 10m. No identified GDEs in the area

Conservation Areas No Red Book or Bush Forever sites in the area

Boonanarring Nature Reserve (400m east of RGPF, 10m east of 2nd Evaporation Pond)

Bartlett Well Nature Reserve (1.7km northwest) [Register of the National Estate]

One ESA (500m west of the DBNGP tie in point)

No Bush Forever sites in the area

Bartlett Well Nature Reserve (1.7km southwest) [Register of the National Estate and Redbook Area]

Boonanarring Nature Reserve (3.3km south of RGN1)

ESA (3km southwest)

Vegetation Cleared farmland

No DRF or ecological communities of national or state significance

24 weed species identified in the region

One declared weed species within the vicinity of Red Gully activities

Fauna Introduced fauna including stock and feral animals. Vegetated areas could provide habitat to 9 species of native fauna. C&M activities will not impact on significant fauna habitat

Introduced fauna including stock and feral animals. Vegetated areas could provide habitat to 14 listed species of native fauna. C&M activities will not impact on significant fauna habitat



Aspect RGPF RGN1

Heritage Inspections have found that there are no areas of Aboriginal or European heritage in the C&M area

Inspections have found that there are no areas of Aboriginal or European heritage in the C&M area. Red Gully Creek South (300m west) could hold aboriginal significance

Socio-economic Gingin townsite (17km south) Gingin town site (22km south)

Land use within the surrounding region is agricultural and infrastructure including RAAF tracking and communications, DBNGP, Parmelia Pipeline and telecommunications

3.1 Natural Environment

3.1.1 Climate

Gingin has a Mediterranean climate, with wet, mild winters and hot, dry summers.

Mean monthly maximum temperatures for Pearce RAAF Airbase range from 18°C in July up to 34°C in January. Mean monthly minimum temperatures for Pearce RAAF Airbase range from 8°C in July-August up to 18°C in February (calculated from 1940 to 2016 data).

The long-term average annual rainfall is 653.1 mm, occurring predominantly in May to September (1937 to 2016 data). On average the wettest month is July with 133.5 mm and driest month January with 9.7 mm. The mean number of rain days recorded for Pearce is 61 days per year (Bureau of Meteorology, 2017).

The summer wind pattern of the region is dominated by strong easterlies with a late afternoon sea breeze. The winter wind pattern is dominated by westerly, as cool fronts from the Indian Ocean cross the coastline (Bureau of Meteorology, 2017)

3.1.2 Soil

The Interim Biogeographic Regionalisation for Australia (IBRA) divides Australia into 85 bioregions based on major biological and geographical/geological attributes. The RGPF is located in the Southwest Forest Region (Darling Botanical District) of the Southwest Province. Under the IBRA framework this region is divided into four sub-regions or botanical sub-districts, and is located in the Drummond Botanical Sub-district (Beard 1990). This sub-district is further divided into two physiographic units:

o Swan Coastal Plain, and o Dandaragan Plateau Bioregions

The Swan Coastal Plain is essentially a low-lying, infertile sandy coastal plain that is often swampy and contains sand hills. The Coastal Plain is dissected by the Dandaragan Plateau in the north. The soils here are mainly Quaternary aged sand deposits or swamp deposits on the plain, and yellow sandy soils characterise the Plateau (Beard 1990). The Gingin Scarp rises from the Coastal Plain to the Plateau.

The RGPF is located at the base of the Gingin Scarp and extends eastwards onto the Dandaragan Plateau, a triangular-shaped portion situated between the Gingin Scarp and the Darling Fault, comprised of sedimentary rocks. Within this physiographic unit the geology of Dandaragan Plateau is comprised of Jurassic and Cretaceous sandstones, shales and siltstone beds, capped by greensand and chalk (Beard, 1979; King and Wells, 1990). The Dandaragan Plateau is a plain covered by sand and laterite that contains flat-lying Cretaceous aged rocks underneath. Its surface rises to a height of approximately 230 metres near Moore River in the north. To the



south-west the Gingin Scarp forms its boundary. The Plateau is not well dissected, with the sandy surface absorbing most of the rainfall.

The soils in the western portion of the Dandaragan Plateau are described as red and yellow earthy sands over calcareous rocks and siliceous rocks respectively. In the eastern portion of the Plateau the soils are described as sandy acidic yellow mottled soils, which contain ironstone gravel with yellow duplex soils and lateritic sandy gravels. On the lower slopes leached sands occur (Beard, 1979).

3.1.3 Surface Water

Red Gully is located on the border of two hydrographic catchments; the Gingin Brook sub-catchment of the Moore River hydrographic catchment and the Brockman River sub catchment of the Swan-Avon hydrographic catchment.

The Gingin Brook sub-catchment is fed by run-off from the Dandaragan Plateau from which numerous ground-water supplied brooks originate, such as Gingin Brook, Boonanarring Brook and Red Gully Creek. The base of the Gingin Scarp is characterised by a low lying and poorly drained plain and includes a series of lakes and inundated areas such Beermullah and White Lakes (Figure 6).

The Brockman River is fed by the Wannamal Lake systems and multiple seasonal creeks. The Brockman River runs south along the western edge of the Darling Scarp, through the Chittering Valley and flows into the lower Avon River.

The surface water drainage patterns near the site are generally towards the west, reflecting the general slope of the landscape. Flat surface topography and limited rainfall in the area will result in minimal surface water drainage and retention issues at the RGPF. Surface water features are listed in Table 19. Red Gully C&M activities will not impact on surface waters.

Table 19: Surface water features

Feature Distance

RGPF RGN1

Red Gully Creek South 2.6 km to the north 300m west of RGN1

Boonanarring Nature Reserve wetlands and/or riparian zones

Immediately east 3.3 km south

Beermullah Lake 1.8 km >2km

Natural surface water sand seeps Wannamal West Road Sand Seep (across road) on freehold property (640 m)

New Springs Seep (1 km east)

The Red Gully Farm soak – a soak at the end of the Red Gully South Creek, used by the landholder as the farm water source,

300m NE 1km south

3.1.4 Groundwater

Red Gully is situated within the Red Gully sub area of the Gingin Groundwater Area of the Northern Perth Basin. The location overlies the surficial aquifer and Mirrabooka aquifer and the deeper, confined Yarragadee north and Leederville-Parmelia aquifers. A summary of the major hydrogeological units associated with the project is provided in Table 20.



Table 20: Hydrological units associated with the project area

Hydrological Unit Aquifer Type Groundwater Flow System

Expected Depth to Water (m BGL)

Superficial Aquifer Aquifer (where saturated)

Local flow system 0-15 Upper Mirrabooka Aquifer (Poison Hill Greensand)

Minor Aquifer

Gingin Chalk Aquitard N/A Not reported

Lower Mirrabooka Aquifer (Molecap Greensand)

Minor Aquifer Intermediate flow 80

Osborne Formation (Kardinya Shale Member Henley Sandstone Member)

Aquitard / Minor Aquifer Intermediate flow Not reported

Leederville Aquifer Multilayered Aquifer, contains local confining units

Intermediate flow 120

Yarragadee Aquifer Confined Aquifer Regional flow 152

Red Gully C&M activities are not expected to impact any reserves, watercourses or aquifers

The project area is within the Gingin Proclaimed Groundwater Area, proclaimed on 26 September 1975 under section 26B of the Rights in Water and Irrigation Act 1914. This means that water users require a water licence to lawfully abstract groundwater under section 5C of the Act.

3.1.5 Acid Sulphate Soils

Information sourced from the Australian Soil Resource Information System (ASRIS) indicates that the RGPF is located within an area where there is a low to no risk of Acid Sulphate Soils.

3.1.6 Conservation Areas

Significant conservation areas in the region include recommended Red Book reserves, DBCA reserves, nature reserves and riparian vegetation.

3.1.6.1 Red Book Recommended Reserves

Red Book recommendations, released by the EPA between 1976 and 1984, were made on areas to be classed as conservation reserves. These EPA tenures are part of a listing of Crown Land areas identified in 'Conservation Reserves for Western Australia' and identify different systems which the EPA considered to be of environmental significance and proposed conservation areas.

There is one Red Book area 2 km south west of RGN1 (Bartlett Well Nature Reserve). Red Gully C&M activities will not impact on this Red Book Area.

3.1.6.2 Bush Forever

The aim of the Bush Forever policy is to provide a policy and implementation framework that ensures bushland protection and management issues in the Perth Metropolitan Region are appropriately addressed and integrated with broader land use planning and decision-making. This is to secure long-term protection of biodiversity and associated environmental values. The policy recognises the protection and management of significant bushland areas as a fundamental consideration in the planning process, while also seeking to



integrate and balance wider environmental, social and economic considerations. The Red Gully infrastructure is not part of a Bush Forever area.

3.1.6.3 DPaW Reserves

The Bartlett Well Nature Reserve is considered to be an environmental sensitivity, located approximately 1.7 km north-west of the RGPF and 2 km south-west of RGN1. It is located to the east of the Brand Highway, and encompasses approximately 117 ha. Bartlett’s is listed on the Register of the National Estate (Place ID: 17878), and its legal status is given as ‘Indicative Place’.

The Boonanarring Nature Reserve is located immediately south of Wannamal Road West, and is 3.3 km south of RGN1 and immediately east of RGPF. There will be no activities carried out within the Boonanarring Nature Reserve.

The Red Gully C&M activities will not impact Boonanarring or Bartlett Well Nature Reserves.

The western extremity of Red Gully is in excess of 1.8 km from Beermullah Lake and does not impact the Lake system.

3.1.6.4 Riparian Vegetation

The closest riparian vegetation to RGN1 is associated with Red Gully South Creek located 300 m west. The Boonanarring Nature Reserve located east of RGPF has wetlands, predominately located along the western perimeter of the Nature Reserve. Red Gully C&M activities do not impact on the wetlands of the Boonanarring Nature Reserve or Beermullah Lake System.

3.1.7 Environmentally Sensitive Areas (ESAs)

Environmentally Sensitive Areas (ESAs) are described under the Environmental Protection (Clearing of Native Vegetation) Regulations 2004 and are selected for their environmental values.

Figures 4, 5 and 6 provide a regional overview and location specific assessment of environmental sensitivities and registered areas surrounding the Red Gully project area:

ID 4636

o 500 m west of the RGPF export pipeline tie-in to the DBNGP o 3 km southwest of RGN1

Two 5 km east of RGN1

Red Gully C&M activities do not impact on any ESAs.

3.1.8 Groundwater Dependent Ecosystems

An ecosystem is when living organisms benefit from one another via symbiotic relationships. A groundwater-dependent ecosystem is when its nourishment relies on groundwater input. Typical examples of these systems are springs and wetland ecosystems where groundwater reaches the earth's surface.

A previous Groundwater Dependent Ecosystem (GDE) study was undertaken by Rutherford et al (2005) for the Northern Perth Basin. This study considered sites to be potentially reliant on groundwater only if the depth to groundwater was less than 20 m.

Red Gully C&M activities are on cleared agricultural land and do not impact on any GDEs.



3.1.9 Vegetation and Flora

Regionally, Red Gully is located within the Drummond Botanical Subdistrict of the South West Province, as The Interim Biogeographic Regionalisation of Australia (IBRA version 6.1) divides the Australian continent into 85 bioregions and 403 subregions. RGN1 is located within the Swan Coastal Plain bioregion over two subregions, the Dandaragan Plateau (SWA1) and the Perth subregion (SWA2).

RGPF is located on Lot No 5653 owned by Cattamarra Farms Pty Ltd, a company owned 90% by Empire Oil Company (WA) Limited and 10% Wharf Resources Limited. The location is historically cleared agricultural land with little remnant vegetation.

RGN-1 project footprint (currently and prior to drilling), utilises only pre-disturbed track or paddock areas. Some vegetation was pruned along the access track and one tree (Eucalyptus sp.) was removed from the drilling pad during preparation for drilling.

3.1.10 Weeds

Red Gully activities are located within private farmland which has an historical existing weed load. No formal weed surveys have been undertaken however weeds known to occur in the local shire (Chittering) are listed in Table 21. The weeds surrounding RGPF and RGN1 are predominantly Avena spp, Arctotheca calendula and Echium Plantagium.

Table 21: Weed species known to occur in Chittering Shire

Weed Species Common Name WoNS WA Declared Pest

Acacia longifolia Sydney Golden Wattle Nil Nil

Arctotheca calendula Capeweed Nil Nil

Asparagus asparagoides Bridal Creeper WONS Declared Pest

Avena spp Wild and Bearded Oats Nil Nil

Babiana angustifolia Baboon Flower Nil Nil

Cortaderia selloana Pampas Grass Nil Nil

Cynodon dactylon Couch Nil Nil

Echium Plantagium Paterson’s Curse Nil Declared Pest

Ehrharta calycina Perrenial Veldt Grass Nil Nil

Eragrostis curvula African Lovegrass Nil Nil

Genista linifolia Flax-leaf Broom WONS Nil

Gladiolus undulatus Wavy Gladiolus Nil Nil

Gomphocarpus fruticosus Narrow Leaf Cotton Bush Nil Declared Pest

Hyparrhenia hirta Tambookie Grass Nil Nil

Leptospermum laevigatum Australian Teatree Nil Nil

Lupinus cosentinii Blue Lupin Nil Nil

Moraea flaccida One-leaf Cape Tulip Nil Declared Pest

Rubus sp Blackberry WONS Declared Pest

Typha orientalis Bulrush Nil Nil

Watsonia mentana var bulb Bulbil Watsonia Nil Nil



Weed Species Common Name WoNS WA Declared Pest

Zantedeschia aethiopica Arum Lily Nil Declared Pest

Cenchrus ciliaris Buffel Grass Nil Nil

Freesia sp Freesia Nil Nil

Euphorbia terracina Geraldton Carnation Weed Nil Nil

The risks of establishing new weed populations as a result of Red Gully C&M activities can be considered to be very low, given that:

Numerous established weed population are already in place in the region

Pre-mobilisation hygiene protocols are in place for earthmoving vehicles and vehicles mobilising from outside the area

The activity will not be accessing any nature reserves and strictly remain within pre-disturbed areas

Any import materials will originate from sources managed to ensure low weed risk

All access to RGPF and RGN1 is in accordance with the Empire Hygiene Management Procedure which requires all vehicles and equipment to be inspected prior to initial mobilisation to the project area (at point of departure). The inspection will be completed by the vehicle owner/driver or supervisor, in line with guidance provided on the Empire hygiene inspection form.

3.1.11 Dieback

The potential for Phytophthora cinnamomi (dieback) occurrences were suggested for the region by Woodman (2008), however a hygiene survey of the entire Red Gully Project area was subsequently undertaken by Glevan (2013) between September 2012 and February 2013 (in preparation for the Wannamal seismic survey) and no areas infested with dieback were observed.

The risks of establishing new dieback areas as a result of this program can be considered to be very low, given that:

Pre-mobilisation hygiene protocols are in place for earthmoving vehicles and vehicles mobilising from outside the area

The activity will not be accessing any nature reserves and strictly remain within pre-disturbed areas

Access track maintenance will not be undertaken under wet conditions

3.1.12 Fauna

Red Gully C&M activities are located on cleared agricultural land cultivated for over 100 years. Fauna searches of the DEC’s Threatened Fauna database and EPBC Protected Matters of National Environmental Significance database were generated for the Red Gully area in July 2015. The searches identified 14 listed species that may occur in the area or have previously been recorded in the in the area. A list of the species, their conservation status and assessment of potential impact from C&M activities are provided in Table 22.

Table 22: Regionally Threatened and Priority Fauna Potentially Occurring in the Red Gully Area

Species Common Name Conservation Status (DPaW / EPBC)

Potential Impact

Calyptorhynchus latirostris

Carnaby’s Black Cockatoo

Threatened / Endangered

Negligible, as remnant vegetation and breeding stands will not be disturbed

Dasyurus geoffroii

Chuditch / Western Quoll

Threatened / Vulnerable

Negligible, as remnant vegetation will not be impacted



Species Common Name Conservation Status (DPaW / EPBC)

Potential Impact

Galaxiella munda Western Mud Minnow

Threatened Negligible, as the area is not within a wetland area

Falco peregrinus Peregrine Falcon Schedule 4 Negligible, as remnant vegetation will not be impacted

Morelia spilota subsp. imbricata

Carpet Python Schedule 4

Priority 4

Negligible, as remnant vegetation will not be impacted

Isoodono besulus subsp. fusciventer

Southern Brown Bandicoot

Priority 5 Negligible, as remnant vegetation will not be impacted

Ardeotis australis Australian Bustard Priority 4 Negligible, as remnant vegetation will not be impacted

Macropus irma Western Brush Wallaby


Rostratula australis

Australian Painted Snipe

Endangered Negligible, as remnant vegetation will not be impacted

Westralunio carteri

Freshwater Musse Priority 4 Negligible, as wetlands will not be impacted

Leioproctus contrarius

Australian Bee Priority 3 Negligible, as remnant vegetation will not be impacted

Leipoa ocellata Mallee fowl Vulnerable Negligible, as remnant vegetation will not be impacted

Neelaps calonotos

Black-Striped Snake


Throscodectes xederoides

Mogumber Bush Cricket


Notes on conservation status: 1. Conservation codes under the Environment Protection and Biodiversity Conservation Act 1999 (Cwlth):

Vulnerable (VU) – A taxon is Vulnerable when the best available evidence indicates that it is considered to be facing a high risk of extinction in the wild.

Endangered (EN) – A taxon is Endangered when the best available evidence indicates that it is considered to be facing a very high risk of extinction in the wild.

Migratory (M) – Species migrates to, over and within Australia and its external territories. 2. Conservation codes under the Wildlife Conservation Act 1950 (WA):

Schedule 1 (S1) – Fauna that is rare or is likely to become extinct.

Schedule 3 (S3) – Birds that are subject to an agreement between the governments of Australia and Japan relating to the protection of migratory birds.

Schedule 4 (S4) – Fauna that is in need of special protection. 3. Conservation codes assigned by the DPAW:

Priority 4 (P4) – Taxa that are considered to have been adequately surveyed, or for which sufficient knowledge is available, and that are considered not current threatened or in need of special protection, but could be if present circumstances change.

A search of the DBCA Threatened Fauna database was also undertaken for a number of Empire’s seismic surveys in the EP389 Permit Area by Woodman Environmental Consulting (2008). These surveys covered a total area of around 60 km2. These surveys indicated the potential occurrence of the species presented in Table 22 in the Red Gully area. Of the species identified, the Carnaby’s Black-Cockatoo, Calyptorhynchus baudinii, is listed as



both an Endangered Bird Species, and Vulnerable Bird Species under the Environment Protection and Biodiversity Conservation Act 1999. Chuditch Dasyurus geoffroii is listed as a Vulnerable Bird Species.

These species will not be impacted by Red Gully C&M activities as the affected area is small and within cleared farmland that has had 100 years of farming activities on it.

There is also the potential for introduced fauna species that are known to occur in the area which may include mice, rats, rabbits, foxes, feral dogs and feral cats.

3.2 Cultural Heritage

3.2.1 Aboriginal Heritage

Red Gully C&M activities are located within the Yued Aboriginal People registered Native Title Claimant on the National Native Title Tribunal register (registry number WC1997/071) over a 29 000 km2 area under the provisions of the Native Title Act 1993. The South West Aboriginal Land and Sea Council (SWALSC) is the native title representative group for traditional owners located around the project area.

Two Aboriginal Ethnographic/Archaeological Surveys have been recorded over the site of the previous Seismic Surveys and drilling locations within the EP389 Permit and no aboriginal sites on the freehold land have been recorded. The Heritage Surveys were:

o Survey 2599 (01 Dec 1997) Red Gully Archaeological Survey for Empire Oil and Gas NL (proponent) o Survey 2620 (01 Dec 1997) Red Gully Ethnographic Survey for Empire Oil and Gas NL (proponent) o Quatermaine Consultants, Addendum to the Report on an Archaeological Survey for Aboriginal Sites in

the Red Gully Project Area, Gingin. Prepared for Empire Oil & Gas, by Sally McGann. April 1999 o Quatermaine Consultants, Addendum to the Report on an Archaeological Survey for Aboriginal Sites at

the Tangletoe Project, Bullsbrook North Section. Prepared for Empire Oil & Gas, by Sally McGann. January 2000

The Aboriginal Heritage Inquiry System (AHIS), maintained by the DAA, was interrogated for indigenous sites of archaeological and ethnographical significance within a 5 km shape encompassing the drill site and access track. The sites identified were:

Gingin Brooke Waggyl Site (20008)

Moore River Waugal (20749)

Chandala Brook (21620)

Ethnographic and Archaeological surveys with follow-up correspondence with DAA confirmed that no sites of ethnographic importance were identified within the project footprint. The reports indicate that some archaeological sites (scatters) occur in the region, but these were always restricted to the edges of rivers, creeks and brooks and none were found within the project footprint area. Red Gully Creek South has been identified as a site with the potential for aboriginal significance.

The Red Gully C&M activities do not impact on any Aboriginal Heritage sites and is wholly contained within Freehold land.

3.2.2 European Heritage

There are no European culturally significant sites located within the project area.



3.3 Socio-economic Environment

The township of Gingin is located approximately 17 kilometres south of the licence area. Gingin is the local administrative centre for the Shire, as well as being one of the oldest towns in the State, and comprises a resident population of approximately 4,500 persons.

Red Gully C&M activities are situated within the Boonanarring agricultural region, Gingin, which contains a diverse range of agricultural uses. It is located on private farming land dedicated to sheep grazing. Access can be gained to the site along Wannamal Road West from the Brand Highway (as shown in Figure 1). In addition, there are several infrastructure facilities in the vicinity including but not limited to the DBNGP, the DBNGP corridor, the Parmelia Gas Pipeline, Brand Highway, above ground power lines, Royal Australian Air force (RAAF) tracking and communications facilities and telecommunications.

4 Environmental Risk Assessment and Management

A preservation assessment workshop was undertaken on 30th January 2018. The participants are listed in Table 23.

Table 23: Preservation Assessment Workshop

Participants Role Organisation

Vaughn Hinkley HSEQ Manager Mineral Resources

Cameron Goodchild Person in Charge Upstream PS

Yongzhuang Li Production Engineer Mineral Resources

Joseph Derrij Senior Production Engineer Mineral Resources

Rowan Hill Principal Process Engineer Mineral Resources

Stephen Swindells Regional Manager - WA Upstream PS

Peter Kroeger Graduate Maintenance Engineer Upstream PS

Hafiz Mehmood AIM Engineer Upstream PS

Kyren Tierney Operator / Maintainer Upstream PS

The workshop focussed on the methods of preservation and additional work required to develop a preservation plan and associated C&M activities schedule. The output of the workshop and the existing EPs were utilised to prepare this C&M EP:

Red Gully Gas Processing and Production Facility Environment Plan [EGO-HSE-RGPF-EP-001 Rev 5]

Management of Red Gully North-1 Environment Plan [EGO-HSE-RGN1-EP-002 Rev 4]

The risk assessment developed following the preservation assessment workshop report was reviewed 28th February 2018 by:

Vaughn Hinkley (MRL HSEQ Manager)

Yongzhuang Li (MRL Production Engineer)

Angus Walker (MRL General Manager – Oil & Gas)

Andrea Wills (Upstream PS Senior Environmental Advisor

At this time, the aspects, sources of risk and potential environmental impacts identified were assigned a risk, mapped utilising the Empire Risk Matrix (Appendix A). The management measures / controls identified in the preservation assessment workshop to reduce the environmental risks to ALARP were risk mapped to identify



where further controls were required to be investigated. Identified management measures / controls were pursued until the residual risk was deemed acceptable. The resulting risk assessment table is presented in Table 25.

Issues identified and assessed included:

Security

Fire

Soil and Landform

Noise Emissions

Air Emissions

Light Emissions

Physical Presence of Infrastructure

Physical Presence of Transport

Vegetation

Weeds

Fauna

Waste

Landowner / Socio-Economic

Groundwater

Surface Water

Heritage

Chemical Storage, Handling and Transport

Issues identified but not further assessed are presented in Table 24.

Table 24: Issues not Requiring Further Assessment

Aspect Potential Impact Reasoning

Asbestos Air and soil contamination due to an uncontrolled release of asbestos into the environment

Red Gully is new build, there is no asbestos located on site

Phytopthorra cinnamomi Vegetation / habitat loss due to the spread of Phytopthorra cinnamomi

Red Gully access is on cleared farmland only

Subterranean fauna Impact on subterranean fauna All ground disturbing activities are superficial

Acid Sulphate soils Acidification of ground water and surface water

No dewatering activities are undertaken during C&M activities

Noise Emissions Complaint from stakeholders or disturbance of fauna due to C&M activities

Minimal noise associated with C&M activities (all conducted during day light hours):

Vehicles

Irregular air compressor

Light Emissions Disturbance of fauna or complaint from landowner

No light emissions during C&M activities (plant lighting not in use)

All activities undertaken during daylight hours

The risk assessment for surface water and groundwater aspects was reviewed and revised 10th April 2018 by:



Vaughn Hinkley (MRL HSEQ Manager)

Yongzhuang Li (MRL Production Engineer)

Angus Walker (MRL General Manager – Oil & Gas)

Andrea Wills (Upstream PS Senior Environmental Advisor

Table 25 was updated to incorporate the assessment of these aspects.



Table 25: Risk Assessment Table

No. Aspect Source of Risk Potential Impacts

Risk Ranking (Pre Treatment) Controls Risk Ranking (Post Treatment)

Consequence (0-5)

Likelihood (A-E)

Identified Risk Description Consequence

(0-5) Likelihood

(A-E) Residual Risk

1 Security Sabotage Spills and soil

contamination Greenhouse gas emissions

4 D Extreme

[4D]

RGPF and wellhead areas are securely fenced with locked gates

Tree valves locked on wells

Monthly (security) visits from personnel to location for inspections

Minimal equipment on site that can be handled

Farm management presence

MRL have real time monitoring of the RGPF entry and plant via cameras linked to MRL’s Perth office

Access is to be obtained from MRL prior to entering C&M sites

Stock fencing and access gates enroute to RGN1

RGN1 4km inland from main road – no road signage to identify location

Plant and flow lines contain nitrogen

Diesel tank drained and hose removed

4 A Medium

[A4]

2 Fire Bushfire

Loss of fauna, habitat or personnel

Equipment damage Loss of containment

Not risk assessed as no credible risk of fire originating

from plant

Large pad surrounded by cleared farmland

Firebreaks maintained annually

All grasses within facilities, well pads and firebreaks to be at a height no more than 100mm

Monthly inspections include checking firebreaks

Empire vehicles have access to fire extinguisher

Presence of farming management within the area

Ongoing communication with Gingin Shire (Bushfire Brigade)

Weed control management in accordance with Weed Hygiene and Control Procedure [MRL-EN-PRO-0007]

Emergency Response Plan [EGO-ER-002] in place

Cattamarra farm (adjacent to site) managed to reduce fire load on this external to site

Plant and flow lines contain nitrogen

3 Soil and

Landform

Soil erosion Vehicles

Vegetation clearing (Fire breaks, weed spraying)

Weather Third Party

Ground disturbance activities

Loss of habitat Exceeding approved license

(clearing permit) Erosion

Dust Soil compaction Local complaints

4 C High [4C]

Pipeline markers and authorized entry only signage

Adherence to designated tracks

Berm around the RGN1 well head is maintained

HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649


Erosion remedial works undertaken where erosion rills are greater the 0.3m x 10m

Excavation/penetration procedure and PTW in place for ground disturbing activities (e.g. pad remedial activities)

Cleared areas kept maintained

Wells, RGPF and evaporation ponds are fenced

Monthly inspections include check all sites including access tracks

Access tracks maintained

Speed limit restricted to 20km/h on well pads and facility

1 C Medium

[1C]

4 Air Emissions Vehicle / stationary engine

exhaust Adverse greenhouse gas

emissions 1 E

Medium [1E]

Low volume of vehicle movement

No gas fired equipment operational

External protective coating on pipeline and flow line

No gas venting

All vehicles regularly serviced in accordance with maintenance servicing schedule

HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649

Emissions reporting (including NGERs and quarterly emissions and discharges reporting)

Cathodic protection on pipeline

Plant and flow lines contain nitrogen (inert gas)

1 A Low [1A]

5 Physical

Presence Of Infrastructure

Red Gully Infrastructure Potential impact on locals

and tourists Reputation

2 C Medium

[2C]


Minimal activities on site (monthly)

Minimal equipment on site

Stakeholder engagement

1 B Low [1B]

6 Physical

Presence Of Transport

Vehicle collision Weather

Driver fatigue Poorly maintained access

roads

Spill after vehicle accident – soil contamination

Dust & vehicle movement Weed transfer Road damage

3 C High [3C]


Short duration associated with any rectification activities

Access only via designated roads, tracks and easements

Infrastructure located on private land

Signage identifying corners and hazards

Speed limits in place

Flat roads and lack of blind spots

Access to infrastructure is from a secondary (non-major) roadway


1 A Low [1A]

7 Vegetation Clearing to maintain

existing cleared areas Unplanned clearing

Over-clearing Impact on rare flora Disturbance of fauna

habitat Disturbance to cultural

heritage areas

2 C Medium

[2C]

Hard stand areas with minimum re-growth

Clear within existing cleared area only

Clearing undertaken in accordance with a permit or relevant exemption

Fenced areas to ensure access to cleared areas only

2 A Low [2A]



No. Aspect Source of Risk Potential Impacts

Risk Ranking (Pre Treatment) Controls Risk Ranking (Post Treatment)

Consequence (0-5)

Likelihood (A-E)

Identified Risk Description Consequence

(0-5) Likelihood

(A-E) Residual Risk

8 Weeds Introducing soil for road or

site stabilisation Vehicle movement

Landowners concern / complaints·

Introduction of weeds 2 D

High [2D]


Vehicles stay along designated roads and well pads

Stakeholder consultation

Fenced areas to ensure access to cleared areas only

Locally sourced borrow material from borrow pits maintained to minimize the risk of the transfer of weeds (topsoil is removed prior to extraction)

2 B Medium

[2B]

9 Fauna

Vehicle collision Behavioural disturbance due

to physical presence Fauna drowning

Effects of chemicals

Dead or injured animals 2 D High [2D]


Traffic signage (including speed limits) on access roads

Infrastructure not operational

No light emissions during C&M activities (plant lighting not in use)

Fauna egress matting in turkey’s nest and evaporation ponds

Cellars have grated covering and matting over the grating

Fencing around infrastructure

Open pipework capped

Most chemicals taken off site, remaining chemicals contained and secured on site

Waste containment covered, secured and disposed offsite

Wells, RGPF and evaporation ponds are fenced

No human interaction with animals

No routine night time driving

1 B Low [1B]

10 Waste

Incorrect disposal of site waste

Disposal of contaminated soil

Litter Fauna injury/fatality Soil contamination

2 C Medium

[2C]

Minimal waste generated during C&M activities

Waste (minimal associated with C&M activities) where stored on site (unusually taken off site immediately) is segregated (hydrocarbon, recyclables, metal, general) and containers covered, secured and waste disposed by a licenced waste contractor with records showing type and location of waste disposal retained

Induction for personnel includes waste disposal

Good housekeeping practices on site

Fenced infrastructure

RGN1 cuttings sump liquids removed and disposed offsite prior to C&M

Procedure for removal of liquids from site

Disposal of chemicals in accordance with relevant SDS

PFW transferred to evaporation pond or taken offsite by licenced contractor for disposal

Quarterly E&Ds report includes waste data

1 A Low [1A]

11 Landowner

Socio-Economic

Inadequate consultation Working outside of scope

discussed with stakeholder

Loss of land access Loss of Income or land

value Loss of reputation for

organisation

2 C Medium

[2C]


Access agreement

Empire Oil & Gas (NL) Community Relations Policy EGO-POL-002

Access tracks maintained

Speed limits adhered to

Infrastructure fenced to ensure access to cleared areas only

Minimal activity

Empire ensure that all approvals are in place (DMIRS, DWER, DoH, Shire of Gingin etc.)

1 B Low [1B]

12 Groundwater LOC from cuttings sump

LOC well integrity Ground water contamination

3 B Medium

[3B]

Monthly annulus pressure monitoring

Quarterly ground water monitoring

Maintain freeboard levels in the evaporation ponds (300 mm)

1 A Low [1A]

13 Surface Water LOC from cuttings sump /

evaporation ponds Surface water contamination

1 B Low [1B]

Monthly inspections of Red Gully infrastructure


If breached, evaporation ponds flow away from any surface water

1 A Low [1A]

14 Heritage LOC Surface water

contamination of Red Gully Creek

4 B High [4B]


Heritage Management Plan in place [14411-HMP-001]

Access track and well pad are fenced to ensure access to cleared areas only

2 A Low [2A]

15

Chemical Storage,

Handling and Transport

LOC Groundwater

contamination 3 B

Medium [3B]

The minimal volume of chemicals on site are on impervious hardstand

All chemicals on site are not visible from outside the facility

A spill kit is stored in the workshop

There is an SDS available on site for all hazardous chemicals

OSCP available to personnel with personnel aware of its requirements

No diesel storage or refueling activities on site

1 A Low [1A]



4.1 Risk Management and Justification of ALARP

The risk management and As Low As Reasonably Practicable (ALARP) justification adopted during risk assessment is presented below. ALARP can be defined as the point where the cost involved in further reducing the environmental impacts and risks of the activity would be highly disproportionate to the environment benefit gained. The principle arises from the reality that resources are finite and should focus on reducing the environmental impacts and/or risks that will deliver the best environmental outcomes possible.

A key decision-making tool that can assist in determining ALARP levels are achieved is to conduct a cost benefit analysis which will compare the costs associated with various options along with their inherent environmental benefits, this process helps guide decision making to ensure the environmental risks are acceptable and reduced to ALARP.

The approach undertaken towards risk management for each aspect involves a review of the residual risk post treatment to determine if the environmental impacts and risks of the activity will be managed to an acceptable level. Where additional implementation measures are necessary to reach a level of acceptability they have been considered and adopted.

4.1.1 Security

Security was deemed the highest risk during all workshops. Significant attention was paid to minimising the risk to the environment associated with third party access to Red Gully infrastructure. The key measure taken was to purge hydrocarbons (reducing LEL to ALARP) from the plant and flowlines and nitrogen blanket. Non-required equipment and chemicals have been removed from site and all remaining loose items have been stored in secure locations.

The RGPF and well head areas continue to be securely fenced with locked gates.

Access to these sites require MRL authorisation. In addition to the farm management presence in the C&M area, monthly inspections of all C&M areas (GGW1, RG1, RGN1, flow line, pipeline, RGPF) will be undertaken by a MRL representative. The inspections undertaken will include security elements of all areas, including all of the locked groundwater monitoring bores to ensure there has been no sabotage (with the potential for groundwater contamination).

The suspended RGN1 well is located 1.4 km north of Wannamal West Road on private farmland with no signage on Wannamal Road to identify the well location. The tree valves on the well head will continue to be locked and the well head within securely fenced, locked, compounds. The access track has stock fencing and access gates along it’s route, to discourage third party access. This physical separation, along with the existing security barriers and inspection routine, was deemed ALARP during risk assessment.

The GGW1 and RG1 wells are located adjacent to Wannamal West Road so do not have the physical separation of the RGN1 well. As GGW and RG1 wells are shut-in rather than suspended, third party interference with well heads was deemed the greatest security risk. The tree valves on the well heads will continue to be locked and the well heads within securely fenced, locked, compounds. In addition to the locked tree valves and securely fenced, locked well head compound, two cameras with real time feed to MRL’s Perth office are installed at the track entrance to this location. Other security management measures continue to be assessed and those deemed appropriate to reduce the residual risk will be implemented.

Suspension of the wells was considered but the proposed duration of the C&M period does not warrant this measure. The DMIRS Resources Branch (Wells) have assessed the well status and deemed that suspension of GGW1 and RG1 is not required in the first twelve months of C&M.

With respect to the above, the security risk associated with C&M activities was deemed acceptable.



4.1.2 Fire

The major risk of fire identified was an external sourced bushfire. Preservation methods have been such that a bushfire will not be escalated due to C&M infrastructure (including removal of hydrocarbon valves and nitrogen blankets). The only C&M activity considered to be a possible fire source was vehicles. However, vehicles are diesel, stay on access tracks and Empire vehicles have access to a fire extinguisher.

All C&M infrastructure have large pads and are surrounded by fire breaks and predominantly cleared farm land. The fire breaks are checked monthly and maintained at least annually. Weed control management is in accordance with Weed Hygiene and Control Procedure [MRL-EN-PRO-0007] so that weeds are kept to a minimum.

The presence of farming management in the C&M area along with ongoing communication with Gingin Shire (Bushfire Brigade) means that MRL are informed of bushfire risks and events in the area.

The priority in the risk assessment was to ensure that the risk of fire emanating from the C&M infrastructure is minimised and personnel are protected in the event of a fire. Bushfire was the only credible fire risk identified. Quantification of this risk was not undertaken as MRL have no control over the factors contributing to an external bushfire. All controls identified have were considered and implemented. This was assessed as being ALARP and as no further controls could be identified, the residual risk was deemed acceptable.

4.1.3 Soil and Landform

The major risks associated with soil and landform are soil erosion, soil compaction and dust. Risk treatments for erosion deemed appropriate were modifying drainage and raised barriers.

All risk treatments identified are already in place. The risks were risk assessed as HIGH, but with some solid treatments in place, this was reduced to MEDIUM. Further analysis did not raise further management controls and the risk was deemed ALARP. The acceptability of the risks were assessed and based on the number of vehicles (frequency, volume of dust, remote location etc.), the frequency of road maintenance and inspections, the residual risk was deemed acceptable without the need to implement further controls.

4.1.4 Vegetation & Fauna

The risks associated with operations impact on vegetation was assessed as MEDIUM. C&M activities involve clearing of existing cleared areas only (in accordance with Vegetation Clearing Procedure [EGO-HSE-RGPF-HSE-PR-001]) ensuring minimised impact on native flora. The risk assessment identified that if vehicles remained on cleared areas and no new clearing was undertaken, the risk to vegetation was ALARP and the residual risk of LOW is acceptable with no further controls required.

4.1.5 Fauna

Vehicle collision was deemed the highest risk to fauna. The risk treatments implemented during operations have been adopted during C&M. This includes:

Adherence to speed limits

Widespread fencing

Personnel awareness in inductions

Clearing of existing cleared areas only (to preserve fauna habitat)

Cellars have grated coverings (with individual grate hole size of 2cm x 8cm in diameter) which completely cover the cellar area

Cellars have matting over the grating area (with breather holes)

Well head compounds and turkey’s nest are fenced

Fauna escape mechanisms in evaporation ponds and turkey’s nest



Risk assessment identified that by eliminating night time driving during C&M activities will reduce the risk to fauna from HIGH to LOW, a point that was deemed ALARP. Fauna collision or entrapment is always “possible” regardless of whether any other treatments are implemented so the risk cannot be reduced further.

4.1.6 Weeds

Without risk treatments the likelihood of introducing / spreading weeds was regarded as LIKELY. The following identified risk treatments adopted during operations will continue to be in place to reduce the risk to what has been deemed as ALARP:

Adherence to tracks and well pads

Use of suitable fill material (e.g. gravel for track maintenance) including ensuring that the topsoil from borrow pits has been removed prior to extraction of material underneath

Weed management program (spraying/slashing) in accordance with Weed Hygiene and Control Procedure [MRL-EN-PRO-0007]

The acceptability of the weed risks to operations were assessed and based on the risk treatments implemented and Empire experience within the area the residual risk is deemed to be acceptable without the need to implement further controls.

4.1.7 Air Emissions Venting/Combustion Engines

Air emissions resulting from C&M activities are negligible as:

There is no venting during C&M

Emission sources are either nitrogen blanketed or empty and open to atmosphere

No gas fired equipment will be operational

Low volume of vehicle movement (normally one vehicle one day a month)

All operational combustion equipment is maintained in accordance with the maintenance schedule

External protective coating and cathodic protection on pipeline (which still contains hydrocarbon gas)

No other risk treatments were identified to reduce the insignificant air emissions associated with C&M. Assessment of the risk following risk treatment adoption was therefore deemed ALARP. Based on the nature and scale of the operation minimal emissions are expected to be generated during normal operations. The residual risk was deemed to be acceptable without the need to implement further controls.

4.1.8 Physical Presence

Risks associated with the physical presence of the operation (including infrastructure, transport, light and air emissions) were assessed as LOW. All risk treatments identified were deemed to reduce the risk to ALARP:


Minimal activities on site (monthly)

Minimal equipment on site


Short duration associated with any rectification activities

Access only via designated roads, tracks and easements

Infrastructure located on private land

Signage identifying corners and hazards

Speed limits in place

Flat roads and lack of blind spots

Access to infrastructure is from a secondary (non-major) roadway




The acceptability of the physical presence of C&M activities was assessed and based on the risk treatments implemented and Empire’s operational experience within the area the residual risk is deemed to be acceptable without the need to implement further controls.

4.1.9 Landowner Socio-Economic

Pre-treatment risk for Landowner Socio-Economic impact was identified as being MEDIUM. Empire has a stakeholder engagement structure in place which results in a regular and solid interface with all groups. With stakeholder procedures in place and the excellent relationship that Empire has with these groups, the treatment risk is identified as be LOW and to a level of ALARP.

4.1.10 Humeceptor

The condensate load out bay drains to a Humeceptor via a locked valve and pipe. There is no condensate produced during C&M, so all liquid collected on the load out bay will be uncontaminated. However, risk assessment identified that the current configuration requires a contingency sample point. To achieve this, the drainage outlet modification will be removed creating a sample point on the Humeceptor. With no potential for contaminated liquids being discharged to the environment via the Humeceptor, no other risk treatments were deemed appropriate.

There is the potential for erosion where stormwater is drained into the Humeceptor. This risk is to be managed by controlling the volume of liquids draining from the pad into the interceptor at the locked valve. This was deemed ALARP as the erosion will only occur while the humeceptor is being drained (a manned activity). Additional risk controls will be assessed if erosion occurs that cannot be immediately remediated.

At this point, the residual risk is deemed to be acceptable without the need to implement further controls.

4.1.11 Chemical Storage, Handling and Transport

Pre-treatment risk for chemical storage, handling and transport was determined to be MEDIUM as without risk treatments the likelihood of a spill is LIKELY. The majority of chemicals have been taken offsite with only small volume chemicals remaining in the workshop cabinet. Due to the volume of chemicals involved the consequence of a spill would be MINOR. These chemicals are in a secure storage location and in functional containers. A spill kit is stored in the workshop along with an SDS available on site for all hazardous chemicals. An OSCP is available to personnel with personnel aware of its requirements. These measures were deemed ALARP and as the chemicals are still required on site for C&M activities, the residual risk LOW was deemed acceptable as removal from site was not an option.

4.1.12 Waste

Minimal waste will be generated during C&M activities. The waste strategy is to contain all waste while on site and take for immediate offsite disposal. Where waste is required to be stored on site, it is segregated (hydrocarbon, recyclables, metal, general) and containers covered, secured and waste disposed by a licenced waste contractor with records showing type and location of waste disposal retained. The acceptability of the waste risks to operations were assessed and based on the risk treatments implemented the residual risk is deemed to be acceptable without the need to implement further controls.

4.1.13 Groundwater and Surface Water

Risk controls implemented for Red Gully C&M activities have been deemed to reduce the risk of groundwater or surface water contamination to ALARP.



Rectification works at RGN1 have reduced the risk of surface water and groundwater contamination to ALARP by:

Removing the contents of the cuttings sump, Turkey’s Nest and flare pit

Sampling under the cuttings sump, Turkey’s Nest and flare pit

Excavating affected soil

Disposal of all materials to a licenced waste receiver

This includes:

Providing a nitrogen blanket to vessels, pipework, pipeline and flowline

Emptying tanks

Implementation of security measures

Removing chemicals from site


Removing contents of Evaporation Pond 1 and testing integrity of liner

Monthly annulus pressure monitoring

Monthly inspections of Red Gully infrastructure

Quarterly ground water monitoring

Prior to implementing the above controls at RGPF, GGW1 and RG1, the risk to groundwater and surface water was deemed MEDIUM and LOW. On implementation of the controls above the residual risk to groundwater was deemed LOW and at the point of ALARP. The residual risk was deemed acceptable as no further contamination sources have been identified.

4.2 Risk Classification and Reporting Requirements

Under the definition in the Guideline for the Development of Petroleum and Geothermal Environment Plans in Western Australia the risk consequence of moderate is equivalent to high on the Empire Risk Matrix.



5 Objectives, Standards and Measurement Criteria

Environmental performance objectives, standards and measurement criteria for potential environmental impacts and risks associated with the activity have been developed to allow measurement of Empire’s performance in protecting the environment. These are presented in Table 26.

Table 26: Objectives, Standards and Measurement Criteria

# Risk Environmental Performance Objective

Environmental Performance Standards Measurement Criteria

1 - Minimse the Impact of Operations on the Environment

General Manager to ensure that personnel are aware of the Empire Environment Policy [EGO-POL-003] to ensure that all personnel conduct their activities in a way that minimises the impact of operations on the environment

AIEA confirms that:

The Empire Environment Policy is visible on site for all personnel

The induction contains the Empire Environment Policy

Induction records confirm that all personnel on the monthly manhours report have completed the induction

General Manager to ensure there is an approved EP for all activities as per Petroleum Geothermal Energy Resources (PGER) (Environment) Regulations 2012 Regulation 6 and Petroleum Pipelines (PP) (Environment) Regulations 2012 Regulation 6 to ensure that all personnel conduct their activities in a way that minimises the impact of operations on the environment

AIEA confirms that:

The EP is available to all site personnel

The induction communicates relevant EP conditions to all personnel prior to undergoing activities

Induction records confirm that all personnel on the monthly manhours report have completed the induction

General Manager to ensure all staff, contractors and visitors understand their HSE responsibilities as per the RGPF comprehensive site induction to ensure that all personnel conduct their activities in a way that minimises the impact of operations on the environment including:

No unauthorised impact on flora

No death or injury of fauna

No contamination of surface water

No contamination of ground water

No contamination of soil

AIEA confirms that:

All personnel are inducted (staff, contractors and visitors) prior to work activities on site via records of inductions maintained in MYOSH

Induction includes speed limits, reporting environmental hazards, waste, clearing native vegetation, fauna, weed hygiene, fire, chemical storage and handling and other topics included in Section 7.4 of the Red Gully C&M EP [EGO-HSE-RGPF-EP-001]

General Manager to ensure annual auditing of C&M activities for compliance against the C&M EP [EGO-HSE-RGPF-EP-001] performance objectives and standards as per the Petroleum Geothermal Energy Resources (Environment) Regulations 2012 Regulation 15 and Petroleum Pipelines (Environment) Regulations 2012 Regulation 15 to ensure that corrective actions and improvement opportunities can be identified and implemented to ensure C&M activities do not negatively affect the environment. Audit to include:

Site visit to determine on-site compliance

Documentation review to ensure required documentation is being completed and stored as required

Procedure review to ensure adequacy and availability

Environmental Compliance Schedule [EGO-HSE-REG-014] includes an AIEA

AIEA Report stored in MyOSH (with relevant actions for close out)

All C&M personnel have completed training as per Section 7.4 of the Red Gully C&M EP [EGO-HSE-RGPF-EP-001] to ensure C&M activities do not adversely affect the environment:

MyOSH Familiarisation

Oil Spill Response

Permit Authority

Permit Holder and Work Party

Job Hazard Analysis

AIEA confirms that:

Personnel training records are kept in MyOSH and updated accordingly

AIEA Report stored in MyOSH (with relevant actions for close out) confirms all personnel have completed the training outlined in Section 7.4 of this EP





General Manager to ensure all contractors have applicable competencies for the activities to be undertaken as per Contractor HSEQ Standard EGO-STA-300 to ensure that there are no adverse impacts on the environment associated with contractor activities

AIEA Report stored in MyOSH (with relevant actions for close out) documents all Contractor training records are available to the PIC prior to activity commencement to ensure competencies of personnel is reviewed and filed on site

PIC to ensure there is an authorised entry only signage at plant entrance as per Red Gully C&M EP [EGO-HSE-RGPF-EP-001] and HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649 to discourage unauthorised entry to RGPF

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that there is an authorised entry only signage at plant entrance.

Monthly Inspections undertaken by PIC in accordance with the HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649 to ensure that environmental issues are addressed:

Firebreaks

Access tracks

Chemical storage and handling areas

Liquid stock tank and bunded area

Evaporation Pond

Assessment for the requirement to undertake dust suppression

Evidence of erosion

AIEA confirms that:

Monthly inspection checklists are completed and saved in MyOSH (with relevant actions for close out)

MWO162649 is completed and available in maintenance system history

HSE Inspection and Verification Form confirms all operational checks are conducted on Red Gully C&M sites

General Manager to ensure consultation is conducted in accordance with the Stakeholder Management Plan [EGO-HSE-PLA-005] to facilitate positive relationships with all stakeholders on environmental aspects:

Fire readiness

Noise

Light

Physical presence infrastructure and transport

Vegetation

Weed hygiene

Heritage

Stock movement

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that Stakeholder Engagement has been conducted and recorded in the up to date stakeholder register

2 Legislative non-compliance

Prevent breaches of legislative compliance conditions

General Manager to ensure all Red Gully C&M activities are conducted to ensure there is no pollution of the environment as per Environmental Protection Act 1986 (EP Act) Part V Licence L8766/2013

No unauthorised emissions and discharges

Environmental Monitoring is undertaken

Complete AERs and AACRs are submitted on time

A works approval is in place for all required activities

Department of Water and Environment Regulation (DWER) inspection reports document no non-compliances with Environmental Protection Act 1986 (EP Act) Part V Licence L8766/2013

A DWER AER and AACR is submitted annually (by 28th January) confirming compliance with conditions of Part V Licence L8766/2013

DWER acceptance letter of Empire’s AER and AACR

AIEA Report stored in MyOSH (with relevant actions for close out) confirms there is a copy of L8766/2013 onsite

General Manager to ensure all Red Gully C&M activities are operated in accordance with the Red Gully C&M EP [EGO-HSE-RGPF-EP-001] and the Environmental Compliance Schedule [EGO-HSE-REG-014] to ensure that Empire meet all legislative compliance conditions:

Reporting

Monitoring

Sampling

Inspection

Maintenance

HSE Inspection and Verification Form are completed to ensure legislative commitments in the EP are being captured to enable compliance

AIEA Report (saved in MyOSH) documents no non-compliances with the Red Gully C&M EP

All DMIRS audit reports document no non-compliances

DMIRS acceptance letter/email of Empire’s DMIRS AER





Licencing

Auditing

Document review

All reporting is undertaken by the HSE Manager in accordance with Section 9 of the Red Gully C&M EP [EGO-HSE-RGPF-EP-001] to ensure that Empire meet all legislative reporting requirements for reportable incidents and DWER notifiable incidents and regular reporting as documented on the Environmental Compliance Schedule [EGO-HSE-REG-014]:

DMIRS PEB AER

DMIRS PEB Recordable Incidents

DMIRS Quarterly Emissions and Discharges

DWER AER

NGER Reporting

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that:

DMIRS PEB AER is submitted annually by the 30th October.

DMIRS PEB are notified of reportable Incidents within 2 hours of incident discovery

DMIRS PEB Reportable Incident Reports submitted within 3 days of notification of an incident

DMIRS Monthly Recordable Incident Reports are submitted within 15 days after the end of the month to which it relates

Provide notification to DWER Notification where a Significant Pollution Event has occurred

DMIRS Quarterly Emissions and Discharges Reports are submitted within 15 days after the end of the quarter to which it relates

Ensure NGER Reporting completed annually prior to the 31st of October

The annual abstraction volume is measured to determine compliance with the Rights in Water and Irrigation Act 1914 Section 5C Licences to Take Water GWL181456 (5 ML licenced volume) and GWL170409 (7 ML licenced volume) to ensure the protection of groundwater resources in the Red Gully area by documenting the meter readings on the HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649 by the PIC


The volume of water abstracted (if any) is within licenced volume

The abstraction volume reported in DMIRS AER

A copy of all Licences to Take Water are available on site

3 Security Prevent impact to the environment due sabotage

General Manager to ensure all infrastructure is preserved in accordance with the Preservation Plan (Environmental aspects included in Section 2.7 of the Red Gully C&M EP [EGO-HSE-RGPF-EP-001]) to minimise the hazards posed by the presence of the infrastructure:

No leaks or spills

No open pipework

No security issues

No erosion

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that verification was undertaken that all activities were undertaken during preservation activities in accordance with the Preservation Procedure [24COMHYPPRO013]

PIC to ensure cameras are in place at RGPF plant entrance with a real time feed to MRL’s Perth office to discourage security breaches and provide to police in the event of sabotage (illegal entry, theft, vandalism) as per HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that the HSE Inspection and Verification Form records a visual check has been undertaken to verify that the cameras are in working order

Red Gully C&M areas are checked monthly as per HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649 by the PIC to ensure that security is maintained:

Security cameras are in place and functioning

Gates are closed and locked

Well heads are secure

Buildings are secure

Monitoring bores are secured

Evidence of third party access is recorded

HSE Inspection and Verification Form documents visual inspection of:

All equipment and infrastructure for interference or damage

Security measures in place to ensure secure (including fences, gates, buildings, padlocks)

Cameras are in place, undamaged and operational

Inspection of piping for leakages or signs of damage, pitting, coating deterioration, deformation, bulging etc

Compressor and equipment inspection for any signs of rust, damage etc

gauge readings

Verification of positive isolation from reservoir well

Fire breaks and groundwater monitoring bores

MyOSH actions will be raised for any evidence of sabotage and actions raised to rectify the issue will be tracked to completion





4 Fire Prevent fire originating from Red Gully C&M Activities

PIC to ensure firebreaks around the facility are maintained annually prior to restricted burning period in accordance with Gingin Shire compliance requirements (issued with rates notice) prior to November to prevent the ingress of a bushfire on to Red Gully operations documented on the HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649:

There is 3 meters wide bare earth on boundary


The HSE Inspection and Verification Form document checks (with any corrective actions recorded in MyOSH and tracked to completion) that:

There is 3 meters wide bare earth on boundary


Personnel do not smoke in any areas except the smoking area located outside the facility boundary at the front access gate as per HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649 to ensure no fires originate from Red Gully activities

AIEA Report stored in MyOSH (with relevant actions for close out) confirms no evidence of smoking outside the smoking area

HSE Manager to ensure that current Evacuation and Bushfire Responses are covered in the Emergency Response Plan [EGO-HSE-PLA-008] to instruct personnel to evacuate in the event of a bushfire

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that the ERP is available onsite to all personnel

PIC to ensure that serviceable fire extinguishers are in place as per ERP [EGO-HSE-PLA-008] to ensure appropriate fire response equipment is available:

Fire ready extinguishers stored in warehouse

Out of service extinguishers tagged and stored separately from fire ready extinguishers

Extinguishers are maintained six monthly

HSE Inspection and Verification Form documents that all fire extinguishers on site are in service or tagged out of service

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that in service fire extinguishers are within six monthly service periods and are located in accordance with the ERP

Vehicles and machinery parked in designated areas in accordance with the RGPF site layout [E001-DG-HS-001] to ensure they are not located over combustible materials

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that all vehicles and machinery are parked in designated areas

Incident reports are raised where vehicles or machinery deviate from designated parking areas

Diesel vehicles only on site as per Red Gully C&M EP [EGO-HSE-RGPF-EP-001] to reduce the risk of igniting a fire as outlined in the Red Gully Induction

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that all vehicles on site are diesel (car parks excepted)

Incident reports are raised where diesel vehicles access areas other than the camp and RGPF carpark

PIC ensures that Empire owned site vehicles contain an in-service fire extinguisher as per Red Gully C&M EP [EGO-HSE-RGPF -EP-001] to provide a mechanism for prompt response to a small fire and checked monthly via HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649

AIEA Report stored in MyOSH (with relevant actions for close out) confirms all Empire vehicles have an operating fire extinguisher

HSE Inspection and Verification Form documents that all Empire owned site vehicles contain an inservice fire extinguisher

HSE Manager ensures that current ERP contact list [EGO-HSE-PLA-009] is in place to ensure that contact can be made to relevant stakeholders in a timely manner including contact details for:

DFES

Local Bushfire Brigade

DBCA


HSEQ Manager checks and confirms on a monthly basis that all contact names/numbers are up to date

ERP contact list is available onsite and on Empire server

5 Soil and Landform

Avoid erosion PIC to ensure that pipeline easement inspections as per requirements of the Pipeline Integrity Management Plan [14411-PIMP-001] are undertaken to ensure that the integrity of the pipeline is maintained against LOC for future use:

Provision for visual inspection

Provision for cathodic protection inspections

Provision for DCVG


pipeline markers are maintained at line of site

pipeline inspection record documents check for washouts, ground settlement and third-party activity

issues identified are remediated ASAP or within 30 days





PIC to ensure that access tracks are maintained in accordance with CMMS to maintain the integrity of the tracks and prevent erosion:

At least 2.5m width

Trafficable

Erosion control measures implemented where erosion rills are wider than 0.3m and depth 0.3m

HSE Inspection and Verification Form documents assessment of track trafficability, areas with erosion and measures required to be remediated and a MyOSH action has been raised and tracked to completion where remediation of the track is required

PIC to ensure that erosion control measures are implemented when erosion rills are greater than 0.3m depth by 10m length in accordance with the Red Gully C&M EP [EGO-HSE-RGPF-EP-001] to prevent ongoing landform issues

HSE Inspection and Verification Form assesses erosion and remediation for any erosion rills greater than 0.3m depth by x 10m length are identified a MyOSH action has been raised and tracked to completion where erosion remediation is required to be undertaken

PIC to ensure that all excavation activities are undertaken as per Excavation / Penetration Procedure and Permit to Work (PTW) Procedure [24/HSEQ/GEN/PC/07] to prevent ongoing landform issues

Excavation Permits are completed and approved for the activity

MRL Manager or delegate conducts an excavation permit audit annually (stored in MyOSH (with relevant actions tracked to completion)) to ensure that completed Excavation Permits are in accordance with the requirements of [24/HSEQ/GEN/PC/07] for all activities breaking the ground surface

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that a PTW was in place for all ground-breaking activities

Personnel observe speed limits within fenced compounds (20km/h) and on access tracks (40 km/h) and adhere to access tracks in accordance with Figure 1 and 2 of this EP to prevent ongoing landform issues


There is no evidence of vehicles speeding or driving outside designated areas

Incident reports are raised in MyOSH for any contravention of this requirement

General Manager to ensure all clearing activities undertaken in accordance with Vegetation Clearing Procedure [EGO-HSE-RGPF-HSE-PR-001] and applicable Clearing Permit / legislated exemption to ensure that no erosion issues are created. This includes:

Clearing permit to be in date

Written approval from GM Oil & Gas MRL

No clearing without permission

PTW to be in place for clearing activities


GM MRL Oil & Gas (or delegate) approves any clearing prior to undertaking the activity

All clearing activities have been undertaken in accordance with an applicable clearing permit or the legislated exemption

The clearing register records all clearing activities conducted

The DMIRS AER documents all clearing activities undertaken and the instrument (permit or legislated exemption) of authorisation

6 Air emissions Minimise Air Emissions

General Manager to ensure that operational vehicles are serviced regularly in accordance with vehicle log book maintenance service schedule to ensure that air emissions from these vehicles is minimised

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that vehicle log books record that all vehicles serviced and maintained

7 Vegetation Minimise the Impact of Operations on Vegetation

Personnel observe speed limits within fenced compounds (20km/h) and on access tracks (40 km/h) and adhere to access tracks in accordance with Figure 1 and 2 of this EP to ensure that vehicles do not come into contact with native vegetation




General Manager to ensure all clearing activities undertaken in accordance with Vegetation Clearing Procedure [EGO-HSE-RGPF-HSE-PR-001] and applicable Clearing Permit / legislated exemption to ensure that clearing is minimised. This includes:

Clearing permit to be in date

Written approval from GM Oil & Gas MRL

No clearing without permission

PTW to be in place for clearing activities


GM MRL Oil & Gas (or delegate) approves any clearing prior to undertaking the activity

All clearing activities have been undertaken in accordance with an applicable clearing permit or the legislated exemption

The clearing register records all clearing activities conducted

The DMIRS AER documents all clearing activities undertaken and the instrument (permit or legislated exemption) of authorisation

8 Weeds PIC to ensure that weed management undertaken in accordance with Weed Management Plan [EGO-HSE-PRO-003] to ensure that weeds are not introduced or spread as part of Red Gully

Completed HSE Inspection and Verification Form loaded into MyOSH documents assessment of weed coverage recommendations for any weed control required





Prevent the Spread of Weeds

operations. The Weed Management Plan requires weed spraying and slashing and includes details of:

Types of weeds for the area

Weeds to be sprayed bi-annually on site

Records to be kept on weed control

All weed control activities are documented in accordance with the Weed Hygiene and Control Procedure [MRL-EN-PRO-0007]

Personnel adhere to access tracks and fenced areas in accordance with Red Gully C&M EP [EGO-HSE-RGPF-EP-001] to ensure that weeds are not spread from verges into other areas of the operation

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that there is no evidence of access outside of tracks and fenced areas

General Manager to ensure that fill material (if required) is sourced locally as per Red Gully C&M EP [EGO-HSE-RGPF-EP-001] to ensure that weed seed is not introduced / spread into the area


Records of fill (where purchased) document that it has been sourced locally

Borrow pits must have top soil removed prior to extraction of fill material

9 Fauna Minimise the Impact of Operations on Fauna

PIC to ensure that there is no open pipework on site to prevent fauna entrapment as per HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that all pipework is capped / blocked

HSE Inspection and Verification Form documents check was undertaken for open pipework

PIC to ensure that where waste skips are required, they are covered or caged as per Waste Management Procedure [EGO-HSE-PRO-036] to ensure that fauna do not have a place to scavenge

Waste storage on site not required under normal conditions

General waste is caged or lidded

Solid oily waste is covered

Liquid waste is containerised and bunded


only the minimum necessary waste is stored on site

any general waste and putrescible waste skips are caged or lidded

hydrocarbon solid waste skips (e.g. Rags) are covered

liquid waste is containerised and bunded

Personnel observe speed limits within fenced compounds (20km/h) and on access tracks (40 km/h) and adhere to access tracks in accordance with Figure 1 and 2 of this EP to minimise the risk of impacting fauna




PIC to ensure that RGPF, wellhead compounds and evaporation ponds fence integrity are maintained to prevent the ingress of fauna within the fenced areas as per HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that the integrity of all fences is maintained

HSE Inspection and Verification Form documents a check of all fences and records where repairs are required and a MyOSH action is raised and tracked to completion where fence repairs are required to be undertaken

Personnel maintain the well head cellars with a grated mesh and matting cover (with breather holes) to prevent fauna entry into well head cellars in accordance with the HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649 undertaken by PIC

Completed HSE Inspection and Verification Form confirms that:

grating and matting is in place

where possible trapped fauna is recovered and reported

PIC to ensure that fauna egress installed in turkey’s nest and evaporation ponds to allow fauna to escape from pond as per HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649

HSE Inspection and Verification Form document that fauna egress has been checked and any required repairs to improve serviceability are documented and a MyOSH action is raised where required repairs to fauna egress cannot be undertaken immediately and action is tracked to completion

10 Waste Prevent the Release of Waste to the Environment

Where possible, waste is removed offsite at the time of site inspection activities and if (in the rare event) waste storage is required, waste is segregated and stored in waste skips (covered /caged) and waste receptacles as per Waste Management Procedure [EGO-HSE-PRO-036] to prevent waste escaping to the environment:


only the minimum necessary waste is stored on site

any general waste and putrescible waste skips are caged or lidded

hydrocarbon solid waste skips (e.g. Rags) are covered





Waste storage on site not required under normal conditions

General waste is caged or lidded

Solid oily waste is covered

Liquid waste is containerised and bunded

liquid waste is containerised and bunded

General Manager to ensure that waste management contractor selected in accordance with their work activity scope to ensure that all waste is handled and disposed of in a way that prevents negative impact on the environment as per the Approved Contractor Register


A contractor evaluation checklist has been completed to determine adequacy of waste contractor credentials

Waste management contractor is on the Approved Contractor Register

HSE Manager to ensure that records of waste disposed kept and recorded in the Waste Collection Register [EGO-HSE-REG-003] to provide a method to monitor waste generated and improve management of waste (including reduction and recycling). Register includes:

Waste type

Waste volume

Waste source

Waste destination

Any relevant waste tracking numbers


The Waste Collection Register records waste type, volume, source and destination

Hazardous / contaminated waste tracking receipts are retained

HSE Manager to ensure that evaporation pond liquids are sampled prior to offsite disposal as per the Waste Management Procedure [EGO-HSE-PRO-036] to determine the most appropriate location for disposal. Procedure requires QA sampling in accordance with AS5667 and analysis at a NATA accredited laboratory

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that

PFW sample results have been retained

waste carrier docket is retained and document water volume and date of load-out

11 Stakeholder Minimise impact of operations on surrounding land users

Personnel observe speed limits within fenced compounds (20km/h) and on access tracks (40 km/h) and adhere to access tracks in accordance with Figure 1 and 2 of this EP to ensure that maintenance of tracks and compounds is minimised and prevent stakeholder complaints

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that there is no evidence of vehicles speeding or driving outside designated areas


PIC to ensure that access tracks are maintained in accordance with CMMS to maintain the integrity of the tracks and prevent erosion:

At least 2.5m width

Trafficable

Erosion control measures implemented where erosion rills are wider than 0.3m and depth 0.3m

The HSE Inspection and Verification Form [EGO-FOR-008] documents assessment of track trafficability, areas with erosion and measures required to be remediated and a MyOSH action has been raised and tracked to completion where remediation of the track is required

HSE Manager to ensure that stakeholder correspondence is managed in accordance with the Stakeholder Management Plan [EGO-HSE-PLA-005] to ensure that Empire have records available to enable maintenance of consistent engagement with stakeholders. Details required include:

Stakeholder Project

Stakeholder Names / Contact Details

Nature of Consultation

Date

Topic of Consultation

Consultation Details

Consultation Resolution

Action Required

Status / Resolution


The stakeholder management plan is being adhered to

The Empire stakeholder consultation register is being maintained for all environmental consultation

The DMIRS PEB AER documents environmental stakeholder communications





12 Contaminated Soil / Surface Water / Groundwater

Manage Operations to Avoid Loss of Containment

PIC to ensure that a spill kit is located in the workshop to ensure that any spills of the chemical cabinet chemicals are managed in accordance with the oil spill contingency plan [EGO-HSE-OSCP-003] and checked inaccordance with HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649. The 180 L spill kit must contain:

soc

absorbent pads

gloves

safety goggles

plastic bags

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that a spill kit is located in the workshop and contains (as a minimum) a soc, pads, gloves, safety googles and disposable bags

PIC to ensure loss of containment is prevented by ensuring that:

Minimal chemicals stored on site are secured in the chemical cabinet in the workshop to ensure risk or spills and third party access is minimised

All chemicals are transported and handled on site in accordance with the Hazardous Material Procedure [EGO-HSE-PRO-012] and Safety Data Sheets (SDSs) to ensure the protection of soil and personnel

Disposal tracking receipts from a Licensed Waste Contractor will be retained to provide evidence of compliance with controlled waste tracking requirements


HSE Inspection and Verification Form [EGO-FOR-008] documents a visual check of chemical cabinet contents to ensure individual container integrity is maintained

There is an SDS available in the workshop for all chemicals held in the chemical cabinet

No bulk chemicals have been brought on site without approval

Tracking receipts record volume, type and disposal destination of waste

HSE Manager to ensure all personnel are aware of spill response requirements and procedures outlined in the Empire Oil Spill Contingency Plan (OSCP) [EGO-HSE-OSCP-003] to ensure that personnel are prepared to respond to a spill event:

Immediate response

Response levels

Spill response contacts

Response strategy

Spill response procedures

Monitoring and remediation

Waste Management

Reporting

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that there is a completed MyOSH record documenting that each employee, contractor and visitor has completed an induction outlining spill requirements

PIC to ensure that all leaks and spills cleaned up immediately in accordance with the Empire Oil Spill Contingency Plan (OSCP) [EGO-HSE-OSCP-003] to prevent contamination of soil, groundwater and surface water:

Raising the alarm

Immediate actions

Spill response procedures

Monitoring and remediation

Waste management

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that

There is no evidence of leaks or spills on site

All leaks and spills identified are recorded on the HSE Inspection and Verification Form [EGO-FOR-008]

All leaks and spills are recorded as incidents in MyOSH and all actions are tracked to completion

General Manager to ensure that the OSCP is tested annually or on amendment to the OSCP as per requirement of the OSCP [EGO-HSE-OSCP-003] to ensure that personnel are prepared to respond to a spill event. The drill is a field exercise utilising spill response equipment for a credible environmental spill

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that the annual OSCP drill has been completed and the record form is loaded into MyOSH with all actions tracked to completion

PIC to ensure that the evaporation ponds (emptied prior to C&M) are checked monthly as per HSE Inspection and Verification Form [EGO-FOR-008] under MWO162649 to ensure that there are no anomalies present which could result in a negative environmental impact:

The HSE Inspection and Verification Form [EGO-FOR-008] documents checks of pond liner condition, water level, visual check on pond contents, erosion, fauna egress, pond fencing





Pond liner condition (Pond 2 only)

Water level (rain water only)

Visual check on pond contents

Erosion

Fauna egress

Pond fencing integrity

Pond wall condition

integrity and pond wall condition with any anomalies rectified ASAP and recorded in MyOSH with actions tracked until completion

PIC to ensure that a 300mm freeboard is maintained on the evaporation ponds as per Environmental Protection Act 1986 Part V Licence L8766/2013 to ensure that the evaporation ponds do not over flow


The monthly Inspection check list documents a check to ensure pond levels are maintained with a 300mm freeboard

The Red Gully area is visited after rain events >100mm to check pond level

An incident report is raised in MyOSH where there is a freeboard breach and actions (tracked to completion) are implemented ASAP to prevent damage to the environment

HSE Manager to ensure that Groundwater Monitoring conducted in accordance with the Empire Surveillance Sampling Program [EGO-HSE-PRO-038] to ensure that any adverse impacts to groundwater are identified ASAP. The requirements include:

Testing programme to ensure no contamination has occurred

Monitoring methodology

Periods when monitoring is to be conducted

Roles & Responsibility

Equipment to be used

Locations to test

NATA accredited laboratory testing reports saved as per the Empire Surveillance Sampling Program

Groundwater monitoring results (and interpretation) included in the DMIRS AER which is submitted annually by HSEQ personnel or delegate

Monitoring program effectiveness is reviewed annually and any amendments are documented in the Empire Surveillance Sampling Program and DMIRS AER

Incident report raised in MyOSH immediately if water quality results differ significantly from baseline, with the regulator advised Note: Red Gully groundwater quality results will be compared to the Australian and New Zealand Guidelines for Fresh and Marine Water Quality (ANZECC and ARMCANZ 2000) guidelines for freshwater. Any exceedance of these guidelines will be deemed significant and therefore investigated and reported.

General Manager to ensure wellhead equipment is tested and inspected to identify and prevent any wellhead or downhole issues:

Pressure testing

Greasing and leak checks


All completed work orders for the testing and inspection of wellhead equipment are finalised

HSE Inspection and Verification Form [EGO-FOR-008] documents gauge reading and visual inspection of wellhead

General Manager to ensure cathodic protection survey of export pipeline conducted annually in accordance with the Preservation Plan [RGPF-PLA-001] to determine the effectiveness of the pipeline cathodic protection system as a mechanism to prevent future LOC

AIEA Report stored in MyOSH (with relevant actions for close out) confirms that the work order for the annual cathodic protection survey has been completed



6 Legislation and Other Requirements

Empire are committed to maintaining the highest standards of management, occupational health and safety, and environmental protection. Empire acknowledge their duty of care in all aspects of Red Gully C&M activities and the requirements of the following applicable legislation and industry-related codes of practices.

6.1 Legislation

6.1.1 Western Australian State Legislation

6.1.1.1 Petroleum and Geothermal Energy Resources Act 1967

Petroleum resources activities are required to be licenced under the Petroleum and Geothermal Energy Resources Act 1967. Red Gully C&M activities are licenced under Production Licences L18 and L19.

Petroleum and Geothermal Energy Resources (Environment) Regulations 2012 (Regulation 6) require an EP to be submitted and approved by the DMIRS; this EP has been developed to meet this requirement. All Red Gully C&M activities will be undertaken in accordance with this EP unless an approved EP Bridging Document or Written Notification is in place.

6.1.1.2 Petroleum Pipelines Act 1969

Petroleum pipeline activities are required to be licenced under the Petroleum Pipelines Act 1969. The PP utilised for Red Gully operations is licenced under PL96.

Petroleum Pipelines (Environment) Regulations 2012 (Regulation 6) require an EP to be submitted and approved by the DMIRS; this EP has been developed to meet this requirement. All PL96 activities will be undertaken in accordance with this EP unless an approved EP Bridging Document or Written Notification is in place.

6.1.1.3 Environmental Protection Act 1986 (and Administrative Procedures 2002)

Native Vegetation Clearing

Under the EP Act, clearing of native vegetation is prohibited unless:

o The clearing is exempt under the EP Act or the Environmental Protection (Clearing of native vegetation) Regulations 2004)

o A permit has been granted

Red Gully C&M activities are on existing cleared areas. Minor clearing is required to maintain cleared areas for pipeline easements, firebreaks, access tracks and lay-down areas. These activities are undertaken in accordance with:

o Applicable Clearing Permit – Red Gully Pipeline o The relevant exemption for clearing of existing cleared areas o Section 38 Referral

Environmental Protection Act 1986 Part IV Assessment

Under the EP Act, Section 38 provides that any person (a proponent or third party) may refer a significant proposal (one that is likely to have a significant effect on the environment) to the Environmental Protection Authority (EPA).

The Memorandum of Understanding between the DMIRS and the DWER in relation to the referral of onshore petroleum activities outlines the criteria for referral of onshore mineral proposals.



Empire referred the original proposal for the construction of the RGPF to the EPA for assessment however the EPA returned a decision of ‘Not Assessed. No Advice Given’ on 7 May 2012.

Environmental Protection Act 1986 Part V Licence

The RGPF operates under an EP Act, Part V licence (L8766/2013) issued and regulated by the Department of Water and Environment Regulation (DWER). The conditions of L8766/2013 are included in Table 27.

Table 27: EP Act Part V Licence L8766/2013 Conditions

# Condition Applicability

Produce <90,700 tonnes hydrocarbon per annum Operations

1.1.5 All emissions must be authorised under the licence At all times

1.2.1 The Licensee shall operate and maintain all pollution control and monitoring equipment to the manufacturer’s specification or any relevant and effective internal management system

At all times

1.2.2 The Licensee shall immediately recover or remove and dispose of spills of environmentally hazardous materials outside an engineered containment system.

At all times

1.2.3 The Licensee shall implement all practical measures to prevent stormwater run-off becoming contaminated by the activities on the Premises.

At all times

1.3.1 The Licensee shall ensure that produced water is only discharged into the 2mm thick lined High-Density Polyethylene (HDPE) pond with a permeability of not more than 10-9 m/s.

Operations

1.3.2 The Licensee shall ensure that the evaporation pond is maintained with a minimum top of embankment freeboard of 300 millimetres.

At all times

3.1.3 The Licensee shall record production or throughput data and any other process parameters relevant to any monitoring undertaken.

Operations

2.2.1

The Licensee shall ensure that where waste is emitted to air from the 10.7 m Vent Stack (B-2501) it is done so in accordance with the

conditions of this Licence

Operations

3.2.1

The Licensee shall monitor Methane, Ethane, Propane, Isobutane, n-Butane, Isopantane, n-Pentane, Methyl Pentane, n-Hexane, Hydrogen

Sulphide in the emissions to air from B-2501

Operations

The Licensee shall monitor the quantity of gas vented continuously from B-2501

Operations

5.1.2

The Licensee shall ensure that:

a) any person left in charge of the Premises is aware of the conditions of the Licence and has access at all times to the Licence or copies thereof

b) any person who performs tasks on the Premises is informed of all of the conditions of the Licence that relate to the tasks which that person is performing

At all times

5.1.3 The Licensee shall complete an Annual Audit Compliance Report (AACR) indicating the extent to which the Licensee has complied with the conditions of the Licence for the previous annual period

Annually



# Condition Applicability

5.1.4

The Licensee shall implement a complaints management system that as a minimum records the number and details of complaints received concerning the environmental impact of the activities undertaken at the Premises and any action taken in response to the complaint.

At all times

5.2.1

The Licensee shall submit to the CEO an Annual Environmental Report by 28th January which includes:

Summary of any failure or malfunction of any pollution control equipment and any environmental incidents that have occurred during the annual period and any action taken

Point source air emission monitoring results and volume

AACR

Complaints summary

Annually

5.2.2

The Licensee shall ensure that the Annual Environmental Report also contains:

a) any relevant process, production or operational data recorded under Condition 3.1.3

b) an assessment of the information contained within the report against previous monitoring results and Licence limits

Annually

5.3.1 The Licensee shall ensure that breaches of any limit specified in the Licence are notified to the CEO as soon as practicable but no later than 5pm of the next usual working day

Where applicable

6.1.1.4 Health Act 1911

The septic tanks installed at the RGPF were approved by the Shire Gingin under the Health Act 1911.

6.1.1.5 Rights in Water and Irrigation Act 1914

Abstraction water bores are operated in accordance with instruments issued under the Rights in Water and Irrigation Act 1914:

o GWL181456 (5 ML licenced abstraction volume) o GWL170409 (7 ML licenced abstraction volume)

6.1.1.6 Dangerous Goods Safety Act 2004

The provisions of the Dangerous Goods Safety Act 2004 do not apply to the RGPF while under C&M. A Dangerous Goods Licence [DGS022371] is in place for when the facility is recommissioned.

6.1.1.7 Other Western Australian State Legislation

In addition to obtaining approval from the DMIRS, Empire must comply with legislation and regulations administered by a number of state government bodies.

The key legislation includes:

o Aboriginal Heritage Act 1972 o Biosecurity and Agriculture Management Act 2007 o Bushfires Act 1954 o Contaminated Sites Act 2003 o Heritage of Western Australia Act 1990



o Land Administration Act 1997 o Soil and Land Conservation Act 1945 o Wildlife Conservation Act 1950 o WA Planning and Development Act 2005 o Transfer of Land Act 1893 (WA).

6.1.2 Commonwealth Legislation

6.1.2.1 Environment Protection Biodiversity Conservation Act 1999

The Commonwealth Environment Protection Biodiversity Conservation Act 1999 (EPBC) came into force in July 2000. The EPBC requires a proponent to obtain Commonwealth approval of any action that will or is likely to have a significant impact on Matters of National Environmental Significance. The MNES identified in the Act as triggers for Commonwealth assessment and approval are:

o World Heritage properties o Ramsar wetlands o Nationally threatened species and ecological communities o Migratory species o Commonwealth marine areas o Nuclear actions

There are no MNES that are likely to be impacted by Empire’s activities. Therefore, the activity does not trigger any requirements for approval under the EPBC.

6.1.2.2 National Greenhouse and Energy Reporting Act 2007

The National Greenhouse and Energy Reporting Act 2007 requires proponents to report on their greenhouse gas emissions and production and consumption of energy in accordance with the National Greenhouse and Energy Reporting (Measurement) Determination 2008 where their operations trigger set thresholds. Red Gully C&M activities will not trigger the facility reporting requirements of this legislation. If other Mineral Resources Limited activities trigger reporting, they will include any greenhouse gas emissions (e.g. vehicles) and energy consumption (eg. electricity off the grid) within their report.

6.1.2.3 National Environment Protection Measures (Implementation) Act 1998

Proponents are required to provide an NPI report to the DWER under the National Environment Protection Measures (Implementation) Act 1998 where a facility triggers set thresholds. RGPF is NPI site WA1360 but will not trigger reporting during C&M activities.

6.1.2.4 Native Title

Under the Commonwealth Native Title Act 1993, native title rights and interests may exist on Crown land. However, certain types of leaseholds that confer a right of exclusive possession can extinguish native title over areas of Crown land. Native title is extinguished over freehold and previous exclusive possession acts of the state that are public works (i.e. roads and surrounding area (road reserve) that is necessary for construction and operation of the road).

6.2 International Conventions and Agreements

6.2.1 International Cooperation

To help ensure conservation of migratory birds, the Australian Government has fostered international cooperation through a range of important agreements including bilateral migratory bird agreements with Japan (JAMBA), China (CAMBA) and the Republic of Korea (ROKAMBA), the Convention on the Conservation of Migratory Species of Wild Animals (Bonn Convention), the Ramsar Convention on Wetlands, the Agreement on



the Conservation of Albatrosses and Petrels (ACAP) and through the East Asian - Australasian Flyway Partnership. Empire Oil & Gas has considered the relevant international conventions during project planning:

Significant species may be present in the region of the RGPF, but many of these are migratory waterbirds for which there is little if any suitable habitat. Therefore, the majority of migratory birds would be considered as irregular visitors and as the project footprint is within an existing facility and extensive habitat is nearby, it is considered that there is a low risk of any impact upon conservation significant migratory species.

6.3 Standards

Empire Oil & Gas ensures that where the risk is deemed relevant that they commit to adhering to the most appropriate current Standards, including:

o ISO 31000 Risk Management o ISO 14001 Environmental Management System o AS1940 The Storage and Handling of Flammable and Combustible Liquids o AS3833 The Storage and Handling of Mixed Classes of Dangerous Goods o AS4452 The Storage and Handling of Toxic Substances o AS2885 Pipelines Gas and Liquid Petroleum o AS2430 Classification of Hazardous Areas o AS2381 Electrical Equipment for Explosive Gas Atmospheres - Selection, Installation and Maintenance

Set

8.4 Codes of Practice

The codes of practice which have been referred to in the development of the management strategy outlined in this EP include:

o Australian Petroleum Production and Exploration Association (APPEA) Code of Environmental Practice (October 2008)

o Australian Pipeline Industry Association Code of Environmental Practice, Onshore Pipelines, Revision 3 May 2013

6.4 Other Requirements

Empire has reviewed the following guidelines and publications in support of this application:

o Guideline for the Development of Petroleum and Geothermal Environment Plans in Western Australia, November 2016

o Auditing and Reporting Requirements for Petroleum Activities in Western Australia, Rev 2, October 2012

o Matters of National Environmental Significance, Significant impact guidelines 1.1, 2013, Environment Protection and Biodiversity Conservation Act 1999

7 Implementation Strategy

The objective of the implementation strategy below is to describe how all aspects of the activity will be directed, reviewed and managed to ensure that all potential impacts and risks are continuously reduced to ALARP:

1. Ensure that the agreed environmental performance objectives and standards are met (Section 5) 2. Identify specific systems, practices and procedures to be used to ensure that environmental risks and

effects are reduced to ALARP (Section 7.1) 3. Establish a commitment to the protection of the environment (Section 7.2)



4. Establish a clear chain of command that sets out the roles and responsibilities of Personnel in relation to the implementation, management and review of the EP (Section 7.3)

5. Ensure that each Employee or Contractor working on or in connection with RGPF has the appropriate skills and training (Section 7.4)

6. Monitor, audit and review environmental performance and the Implementation Strategy (Section 7.5) 7. Maintain quantitative records (Section 7.6) 8. Develop and implement emergency and spill preparedness planning and response capability (Section 8) 9. Report on environmental performance (Section 9) 10. Provide for appropriate consultation with relevant government authorities and other interested persons

or organisations (Section 10)

7.1 Systems, Practices and Procedures

Details of Empire systems, practices and procedures relating to the management of all potential impacts and risks of the activity are included in Table 28. The objective of these systems, practices and procedures is to continuously reduce the potential impacts and risks of the activity to ALARP.

Table 28: Empire Systems, Practices and Procedures

Item Objective to achieve ALARP Details of Location

Standard of Practice for Empire sites

To outline the main HSE criteria to be observed by Empire and third-party providers

Empire Environment Policy EGO-POL-003

Empire Site HSE Noticeboard

Empire IMS

Environment Plan To document environmental management of operations

EGO-HSE-RGPF-EP-001

Empire Oil and Gas IMS

PIC Office at site

Emergency Response Plan To provide guidance on the management of an emergency situation

ERP EGO-ER-002

Empire IMS

RGPF site office

Oil Spill Response Plan To provide guidance on the management of a spill

OSCP EGO-HSE-OSCP-003

Empire IMS

PIC office at site

Compliance scheduling – Environmental

To prompt environmental compliance requirements (reporting, auditing, license renewal and document updates)

Environmental Compliance Register EGO-HSE-REG-014

Empire IMS

HSEQ Management System Manual

To provide a framework of the systems, procedures and processes which Empire use to effectively manager operations to meet the objectives of the Empire Environment Policy

EGO-MAN-001

Empire IMS

Preventative Maintenance Management

To provide a preventative maintenance management tool that stores records, schedules maintenance and documents activities undertaken

Preventative Maintenance Management Program

Empire Site Server

MEX



Item Objective to achieve ALARP Details of Location

Standard Operating Procedures To guide personnel on how to conduct tasks to meet environmental performance throughout operations

Empire IMS

Audit management Strategy To plan and document the independent examination and verification of activities, records, processes, and other elements to determine conformity to documented requirements and standards

HSE Audit Plan EGO-HSE-PLA-008

Empire IMS

Training Management To provide the framework for all personnel to have the competency for their respective roles for the management of safety and environmentally critical risks and daily work activities

Training Management Plan (site personnel)

MYOSH Database

Upstream PS IMS

Permit to Work System To ensure facilities are in a safe and environmentally acceptable condition before works starts and is kept in this condition until all personnel involved in the work have signed off completion

Upstream Production Solutions IMS

RGPF site office

Landowner Communications To guide all personnel working at Empire owned assets on interactions with landowners (including tenants and staff)

Stakeholder Management Plan EGO-HSE-PLA-005

Empire IMS

Hazard and Incident Reporting To ensure a systematic approach for reporting and investigating an incident is adopted across the Australian Operations of the company, identify causes of the incident and not attribute blame when conducting investigations, and prevent future incidents

Hazard and Incident Reporting Procedure EGO-HSE-PRO-008

Empire IMS

7.2 Environment Policy

Empire aspires to excellence in Health, Safety and Environmental Performance by its commitment to risk and safety management to ensure safe Red Gully C&M activities. The company’s Environment Policy [EGO-POL-003] (Appendix B) provides a framework for Empire activities and is provided to all personnel including employees, contractors and subcontractors.

7.3 Roles and Responsibilities of Personnel

Table 29 presents the roles and responsibilities of personnel implementing environmental management with reference to Red Gully C&M activities.



Table 29: Roles and responsibilities of personnel

Role Responsibility

MRL GM Oil & Gas Demonstrate “duty of care” through personal example and clearly defined team responsibilities

Ensure that the requirements of this EP are implemented (including seeking advice from HSEQ representatives)

Ensure funds are available to ensure all Operations are conducted in an environmentally responsible manner

Oversee management of Operations from the Empire Perth Office

Ensure regulator reportable incidents are reported

Maintain an easily accessible copy of this EP and the OSCP

Participate in major incident investigations

Ensure that appropriate communications are in place between Empire, Upstream PS, property owners and other stakeholders to keep them informed of project issues and developments that may affect their activities

Direct (or undertake) landowner consultation; this includes verbal and written communication and annual compensation

Establish systems that encourage free and open communication and consultation on HSEQ issues

Production Engineer Demonstrate “duty of care” through personal example and clearly defined team responsibilities


Oversee management of operations from the Mineral Resources Perth Office (including directing Upstream PS staff on required environmental actions)

Regularly attend HSEQ monthly meetings

Establish systems that encourage free and open communication and consultation on HSEQ issues

Participate in major incident investigations as required

Red Gully Site Personnel Demonstrate “duty of care” through personal example

Carry out all aspects of this EP for which they are responsible



Follow good housekeeping procedures and work practices

Never undertake any task that does not meet Empire standards

Ensure that all environmental incidents are recorded and reported to the Empire HSEQ Manager

Verbally report all HSEQ hazards, incidents and near misses to the HSEQ Manager



Role Responsibility

Identify hazards and correct them where it is in their ability to do so

Ensure maintenance is conducted in accordance with the preventative maintenance management system

Participate in training and incident investigation as appropriate

Attend HSEQ meetings and raise any environmental issues

Initiate / participate in emergency response drills

Ensure that all personnel, contractors and visitors have a current comprehensive induction

Ensure contractors and visitors are appropriately supervised

Ensure all licences, certificates and permits for personnel and contractors are current and valid

HSEQ Manager (or delegate) Demonstrate “duty of care” through personal example and clearly defined team responsibilities

Conduct or participate in environmental audits and inspections

Coordinate environmental monitoring activities

Provide advice on environmental matters


Conduct AIEA and participate in regulator environmental audits / inspections

Keep this EP up to date

Act as the contact person for liaising with environmental regulators

Ensure that the requirements of this EP are implemented

Provide legislative advice to the management team on all matters relating to HSEQ to ensure compliance

Lead all incident investigations

Manage the internal HSEQ audit process and monitor the business to ensure legislative and project requirements are met

Contractors and third-party visitors

Undertake induction

Ensure all licences, certificates and permits are current and valid

Understand environmental management relevant to the tasks performed

Follow all Red Gully procedures and requirements

Report all incidents to the PIC

7.4 Training and Competencies

Table 30 outlines the training undertaken to ensure that personnel associated with the activity are aware of their environmental responsibilities and have the appropriate competencies to undertake their role in



compliance with this EP. Training records are stored in MyOSH and personnel training reminders are sent to the applicable coordinators prior to expiry.

Table 30: Training and Competencies

Program Roles Content Summary

RGPF Induction All personnel, contractors and visitors to RGPF

Project background

Environment policy

Permission to visit all sites

Housekeeping

Speed limits

Reporting environmental hazards

Clearing native vegetation

Weed hygiene

Fire

Noise

EP Act Licences

Ground water licences

Fauna

Waste Management

Spill Management

Reportable incidents

Recordable Incidents

Drivers Licences All personnel driving on site Licence applicable to vehicle to be driven

MyOSH Familiarisation MRL Supervisory Representative site personnel

Incident Reporting

Hazard Reporting

Action Tracking

Oil Spill Response MRL Supervisory Representative site personnel

Control, Contain, Clean-up (CCCs)

Clean-up materials equipment specifications, application and usage

Practical drill

Permit Authority PTW Authorities Full PTW process including permit issuing and supervision

Permit Holder and Work Party PTW Holder Familiarisation of process for PTW work party

Job Hazard Analysis MRL Supervisory Representative site personnel

Team based JHA process – hazard and control



7.5 Monitoring, Auditing, Management of Non-Conformance, and Review

7.5.1 Monitoring

7.5.1.1 Routine Site Inspections

Routine site inspection schedule is presented in Table 31. These inspections are to be loaded into MyOSH with any identified actions recorded and closed out by the action owner/s.

Table 31: Routine Site Inspections

Type Frequency Evidence

Routine site inspections in accordance with the HSE Inspection and Verification Form [EGO-FOR-008]

Monthly Completed workplace inspection record form

Well pressure monitoring 6-monthly Pressure reading sheet

Cathodic protection inspection Annually Third party report

D Direct current voltage gradient (DCVG) survey

2-yearly Third party report

7.5.1.2 Groundwater Monitoring

The monitoring bores associated with Red Gully C&M activities are presented in Table 32, Figure 20 and Figure 21. The installation of groundwater monitoring bores will be assessed where recommended by a contaminated sites specialist at Red Gully C&M locations. All future monitoring bores will be installed under the supervision of a qualified hydrological consultant.

The water bores will be monitored with the objective to provide an ongoing measure of groundwater condition so that any potential impacts from Red Gully activities can be measured in accordance with the Groundwater Surveillance Sampling Program [EGO-HSE-PRO-038].

The equipment to be utilised for the sampling will include:

Purge pump

Water level probe

EC probe

Water samples will be submitted to a NATA (National Association of Testing Authorities) accredited laboratory within the required holding period.

The RGPF Project groundwater surveillance sampling program will be reviewed annually to determine the appropriate analyses and testing frequency. Any proposed amendments will be managed through the MOC process and communicated in the Annual Environmental Report (AER).



Table 32: Red Gully Groundwater Monitoring Bores

Monitoring Bore Location Monitoring Frequency Parameters

MW01 GGW1 / RG1

Quarterly (Frequency Assessed Annually)

BTEX, TRH, SWL, EC, TDS, DO and pH

MW02 GGW1 / RG1

MW03 GGW1 / RG1

MW04 RGPF Pond 1 MB

MW05 RGPF Pond 2 MB

MW06 RGPF Upstream MB

RGN1 MB1 RGN1

Figure 20: GGW / RG1 and RGPF Groundwater Monitoring Bores

MW05

MW06

MW04

MW02 MW03

MW01



Figure 21: RGN1 Groundwater Monitoring Bores

7.5.1.3 Air Monitoring

Air monitoring is not required during C&M activities.

7.5.1.4 Laydown Area Completion Criteria Monitoring

Completion criteria monitoring is undertaken in accordance with Table 14 annually until completion criteria is achieved. Results of this monitoring will be included in the DMIRS AER (Section 9.2).

7.5.1.5 Monitoring of Emissions and Discharges

Emissions and discharges will be monitored and reported in accordance with Section 9.4 of this EP.

7.5.2 Auditing

The auditing listed in Table 33 will be undertaken to review the effectiveness of the implementation strategy to determine the environmental performance of the activity and identify continuous improvement initiatives.

Table 33: Auditing

Audit Frequency Scope

AIEA – Field and Desktop Annually Compliance with this EP (objectives, standards and implementation strategy) and environmental licence

Workplace Inspections Monthly Inspect the workplace for compliance with operational requirements

MB1



Audit Frequency Scope

Fire Extinguisher Servicing (External)

6 Monthly Servicing of in-use fire extinguishers in accordance with AS2444 (Portable fire extinguishers and fire blankets)

The annual internal environmental audit will be utilised to:

o Ensure all significant environmental aspects of an activity are covered in the EP o Ensure that mitigation measures implemented onsite are appropriate and reduce environmental

impacts and risks to ALARP o Ensure that management strategies are effective in achieving objectives and standards, and that these

are implemented, reviewed, and amended where necessary o Identify non-compliance and opportunities for continuous improvement o Ensure that all environmental completion criteria have been met prior to completing, suspending or

decommissioning an operation.

7.5.3 Management of Non-Conformance

All non-conformances are entered into the MyOSH database. The information pertains to incidents, hazards, audits and specific actions and tracks these to close out.

Corrective or preventative actions are commensurate with the level of non-conformance identified and is allocated a priority and due date in the database. Email notifications and reminders are provided to personnel assigned to an action for their attention and follow up.

7.5.4 Review

All incidents and non-conformance trends associated with Red Gully Project will be reviewed to determine if any measures can be effectively implemented to further reduce impacts and risks to ALARP, as well as opportunities for improvement. The results of this review will also be reported in the AER. This EP will be reviewed every 5 years.

7.6 Record Keeping

The following records will be kept for a minimum of 5 years and made available to the DMIRS on request:

o Induction and training records o E&Ds records o Chemical stock take o Waste disposal records o Preventative maintenance management program records and work orders o Details of incidents and associated investigations undertaken o Audit and inspection records (including non-conformances and corrective action tracking) o Drill records o Current and archived controlled documents o Regulatory submissions o Daily operations and monthly environmental reports

8 Oil Spill Contingency Plan

The aim of the OSCP [EGO-HSE-RGN1-OSCP-003] is to have in place appropriate measures to minimise the impact of oil spills should they occur during Empire activities. This plan defines the:



o Priority actions to be taken in the event of a spill o Equipment and facilities available for containment, recovery and disposal of spilled oil o The personnel responsible for responding to an oil spill and contact with the relevant authorities o Guidelines for monitoring the impacts of oil spills on the environment and for sub-sequent clean-up

This plan is directed at guiding the actions of personnel in response to an oil spill from liquid spills including diesel, hazardous materials and condensate. The plan will be reviewed every 2.5 years in accordance with regulatory requirements. The OSCP will be tested annually and when the OSCP is amended.

The OSCP was prepared in accordance with Regulation 15(9) of the Petroleum (Environment) Regulation and interfaces with the following documents:

o Emergency Response Plan o Environmental Plan o Oil Spill Contingency Procedure o Hazard and Incident Reporting Procedure o Waste Management Procedure o Crisis Management Plan

The OSCP has been compiled to meet the requirements of the DMIRS ‘Guideline for the Development of an Onshore Oil Spill Contingency Plan, July 2016’.

9 Reporting

A summary of the reporting requirements for RGPF Operations is included in Table 34.

Table 34: Environmental Reporting

Report Required Legislative Requirement Frequency Required

DMIRS PEB AER (Section 9.2) PGER (Environment) 2012 Regulation 16

PP (Environment) 2012 Regulation 16

Annually (31 October)

Reportable Incident Reports (Section 9.3.1)

PGER (Environment) 2012 Regulation 28 & 29

PP (Environment) 2012 Regulation 28 & 29

Within two hours of incident followed by a detailed written report within 3 days

Recordable Incident Reports (Section 9.3.2)

PGER (Environment) 2012 Regulation 30


Monthly (within 15 days of the end of the reporting period)

DWER Notification (Section 9.3.3) EP Act Part V Licence L8766/2013 ASAP (no later than 5pm next usual working day)

Emission & Discharge (Section 9.4)

PGER (Environment) 2012 Regulation 33


Quarterly (within 15 days of the end of the reporting period

DWER Part V Licence AER (Section 9.5)

EP Act Part V Licence L8766/2013 Section 5.2 (of licence)

Annually (28 January)



Report Required Legislative Requirement Frequency Required

Clean Energy Regulator (CER) NGER Reporting (Section 9.7)

National Greenhouse and Energy Reporting Act 2007

Annually (31 October)

9.1 Prestart and Cessation Notification

Table 35 outlines the notifications that will be made by Empire with regard to Red Gully activities via the DMIRS “Lodge an environmental report, notification or report an incident” website.

Table 35: Notifications

Stage Anticipated Date Notification Period

Placement of Facility into C&M On approval of this C&M EP 24hours

Facility Restart - On approval of operations EP

9.2 Activity Reporting (Annual Environmental Report)

An Annual Environmental Report will be submitted to DMIRS PEB annually by 31 October for the Red Gully C&M activities reporting period 1st July – 30th June, to the DMIRS “Lodge an environmental report, notification or report an incident” website or [email protected]. The report will contain:

o A detailed summary of the activities undertaken during the reporting period o Details of any clearing and/or rehabilitation undertaken during the reporting period o A statement of compliance for each objective and standard in the EP including justification based on

the measurement criteria o A summary of audits undertaken, including the findings and corrective actions o A summary of any incidents that occurred (recordable and reportable) and lessons learned o A summary of all E&Ds, and any trends or anomalies o Details of methodology and results of any biological or environmental monitoring undertaken, and a

discussion of any trends or anomalies identified o Details of any new or increased environmental impacts or risks identified during the reporting period o Details of all training and exercises undertaken o Details of all consultation undertaken through the period

9.3 Incident Reporting

9.3.1 Reportable Incidents

Reportable incidents are required to be reported within two hours of the occurrence (or discovery) of a reportable incident to DMIRS PEB verbally on 0419 960 621 or in writing to the DMIRS “Lodge an environmental report, notification or report an incident” website or [email protected]. Incidents regarded as reportable under this EP include:

o Spills of >80 L hydrocarbon to inland waters o Spills of >500 L hydrocarbon to ground surface o Unplanned releases of >500 m3 petroleum in gaseous form o Uncontrolled escape or ignition of petroleum or other flammable or combustible material causing a

potentially hazardous situation

mailto:[email protected]




o Spills of hydrocarbons or other material (including drilling fluids, chemicals, PFW or a substance that has the potential to adversely affect surface vegetation, soil or subsurface ground water) that affects a ground surface area >100 m2

o Incidents with an inherent consequence of high (Empire matrix equivalent of DMIRS moderate) or above:

Sabotage causing loss of containment

Groundwater contamination

Liner failure on a pond

Legal proceedings with a landowner

Blowout

Where significant new or increased environmental impacts or risks have been identified

A written report is required to be submitted within 3 days of the incident to the DMIRS “Lodge an environmental report, notification or report an incident” website or [email protected] The general details required in the written report include:

o Facility name, title, site name or location where the incident occurred o Name and business address of the company that manages the activity o Time and date of the incident o Names and contact details of any witnesses o Name, position and telephone number of person(s) submitting the details o Incident details and description o Activity being undertaken at the time of the incident o All material facts and circumstances concerning the reportable incident that the operator knows or is

able, by reasonable search or inquiry, to find out o Details of any environmental impacts o Immediate response actions taken to prevent further environmental impact o Arrangements for internal root cause analysis investigation o Corrective actions proposed to prevent recurrence of further or similar incidents.

9.3.2 Recordable Incidents

A recordable incident is an incident arising from the activity that breaches an environmental performance objective or standard in the EP (Table 26) for the activity and is not a reportable incident. A written report must be submitted to DMIRS PEB the DMIRS “Lodge an environmental report, notification or report an incident” website or [email protected] within 15 days after the end of the month to which it relates.

The recordable incident report must include records of all recordable incidents that occurred during the monthly reporting period:

o All material facts and circumstances that the operator knows or is able, by reasonable search or inquiry, to find out

o Any action taken to avoid or mitigate any adverse environmental impacts o Any action taken, or proposed to be taken, to prevent similar recordable incidents

A nil incident report is to be submitted where no recordable incidents occurred in the reporting period.

9.3.3 DWER Notification

DER require written notification of the breach of any limit specified by the Licence. The report must be:

o In the template form provided in Schedule 2 of the license o Submitted ASAP but no later than 5pm of the next usual working day





9.4 Emissions and Discharges Report

A quarterly emissions and discharge report is required by the 15th of the month following the quarter to DMIRS PEB the DMIRS “Lodge an environmental report, notification or report an incident” website or [email protected]. Aspects requiring reporting are included in Table 36.

The report will contain details of any tests conducted on monitoring equipment.




Table 36: Emissions and Discharges Reporting Parameters

Aspect Monitoring Frequency Monitoring Methodology

Calibration Details Methodology Justification

Quantification

Diesel Fuel – Vehicles On refuelling activity Meter Diesel Delivery Invoice

Reconciliation Direct measurement <1 kt CO2-e/yr

Solid Waste On disposal Invoice Not required Vendor Measurement –

Financial Transaction <50 m3/yr

Scrap Steel On disposal Invoice Not required Vendor Measurement –

Financial Transaction 200 m3/yr

Liquid Waste As required Invoice Not required Vendor Measurement –

Financial Transaction -

Sewage - Estimate 70 L/d/person Health Act 1911

estimates 540 L/d is equivalent to 8 persons

3,000 L/yr



9.5 DWER Part V Licence AER

DER require a Part V Licence AER. The report is required to be submitted annually by 28 January and must contain:

o A summary of any failure or malfunction of any pollution control equipment and any environmental incidents that have occurred during the annual period and any action taken

o Point source air emissions volume o Point source air emission monitoring results o Annual Audit Compliance Report o Complaints summary

9.6 CER NGER Reporting

Corporations that exceed NGER thresholds must submit an annual report for all facilities (and offices) under their operational control. The report is submitted annually via the CER online reporting tool by 31 October.

10 Consultation

The key principles of stakeholder consultation are:

o Communication: open and effective engagement involves both listening and talking o Transparency: clear and agreed information and feedback processes o Collaboration: working cooperatively to seek mutually beneficial outcomes o Inclusiveness: understand and involve communities and stakeholders early and throughout the process o Integrity: conduct engagement in a manner that fosters mutual respect and trust.

Empire defines stakeholders as any individual or group that is affected by our activities or has the ability to influence the outcomes of specific project objectives. In general, we aim to incorporate the following characteristics in our stakeholder engagement programs:

o All relevant stakeholders are identified (and classified by type and priority) o The ‘stake’ each stakeholder holds is well understood o Stakeholder engagement occurs in a timely manner o Each stakeholder feels appropriately involved o Information is consistent according to stakeholder needs

Empire has developed a Stakeholder Management Plan [EGO-HSE-PLA-005] which records and identifies all relevant stakeholders engaged, the nature of engagement including the level of information provided, the date/s of the consultations, the issues and concerns raised by those stakeholders and how they were resolved. The Stakeholder Management Plan provides mechanisms and processes for stakeholder consultation and resolution of any concerns or complaints for the resolution of impact to the public from the site.

Communication and consultation includes:

o Responses to ad-hoc stakeholder enquiries or complaints about existing activities; o Implementation and management of formal stakeholder consultation programs for proposed new or

revised operations activities, and o Pro-active ongoing engagement with stakeholders outside of formal consultation programs.

All correspondence is entered into the Stakeholder Engagement Register which includes:

o Contact details of the stakeholder o A log of feedback received from stakeholders o A log of Empire response to the feedback o Actions to be completed in seeking mutual acceptance



o A summary of the outcomes of the correspondence (e.g. additional controls implemented as a result)

o A completed check box to be ticked once correspondence is closed-out

Local stakeholder consultation has been undertaken with numerous entities (>100) with respect to the exploration, formal land access agreements, construction and production phases of the site. This consultation has included provision of correspondence regarding various licence and approval applications and direct contact through meetings, informative stakeholder barbeques and phone calls.

Empire are committed to ongoing relationship building and engagement with the community and key stakeholders. This is an ongoing process and one that is pertinent to the organizational philosophy.

10.1 Potential Stakeholders

Empire are continually liaising with the community in order to be cognizant of any other potential stakeholders that may need to be engaged for both current and future works with RGPF.

10.2 Ongoing Consultation

Empire plan to continue direct consultation with applicable stakeholders. This includes (but is not limited to):

o Adjacent Landowners o DBP o DWER o DFES o DMIRS o Local Business owners and service providers o Local Stakeholders o Shire of Gingin

10.3 Historical Consultation

Historically, including during planning, construction and commissioning of the RGPF, consultation has been conducted with:

o Office of Environmental Protection Authority o Department of Environment Regulation – Swan Region, Midwest Region, Industry Regulations o Department of Mines and Petroleum o Mining tenement holders (Kingsreef Pty Ltd / Image Resources) o Landholder for Lot 5550 o Freehold landholders (directly impacted and adjacent) o Main Roads WA o Australian Property Group, Department of Administrative Services o APA Group o RAAF – Pearce and William Town o Shire of Gingin o Yued Native Title Group representatives o Department of Water o Department of Regional Development and Lands o Dampier Bunbury Group o South West Aboriginal Land and Sea Council

10.4 Recent Consultation

Table 37 presents recent consultation (since November 2016) undertaken by Empire on Red Gully operations.



Table 37: 2016 to February 2018 Consultation

Stakeholder Project Names / Contact Details Nature of Consultation

Date Notes & Resolution Action Required

Status / Resolution

DMIRS WMP Petroleum Compliance Brach Email 04/04/2018 New version of WMP submitted to DMIRS Nil DMIRS receipt confirmation receieved 09/04/2018

DMIRS RGN1 Petroleum Compliance Brach Phone 03/04/2018 Notification to DMIRS that an abnormal reading on RGN1 C-Annulus has been identified and Empire are investigating

Provide update

DMIRS notified of suspected faulty gauge 06/04/2018)

DMIRS RGN1 Petroleum Compliance Brach Email 04/04/2018 Empire advised to submit a suspension application for RGN1 VR plug installation MOC

Empire submit suspension application

Letter submitted 06/04/2018

DMIRS Red Gully Activities

DMIRS Petroleum Environmental Branch

Email 29/03/2018 35 RFIs on Rev 0 of the Red Gully C&M EP MRL to amend & resubmit EP

Rev 1 submitted

Landowner Red Gully Activities

Tony Ruse Phone / Letter 26/03/2018 Temporary Access Agreement signed by Empire and Tony Ruse Empire to email agreement

Landowner signed agreement

DMIRS WMP Petroleum Compliance Brach Email / Meeting 23/03/2018 Feedback on WMP via email Meeting on 28/03/2018 requires Empire to address RFIs in a new version of WMP

Update WMP

Ongoing


Arthur Dewar Email 21/03/2018 Notification of planned transport activities on Wannamal Road West for RGN1 Cutting Sump Remediation

Nil


Tony Ruse Email 21/03/2018 Notification of planned transport activities on Wannamal Road West for RGN1 Cutting Sump Remediation

Nil

Shire of Gingin Red Gully Activities

Jeremy Edwards Email 21/03/2018 Notification of planned transport activities on Wannamal Road West for RGN1 Cutting Sump Remediation

Nil


Judith Blenkinsop Email 21/03/2018 Notification of planned transport activities on Wannamal Road West for RGN1 Cutting Sump Remediation

Nil


Gavin Drew Email 21/03/2018 Notification of planned transport activities on Wannamal Road West for RGN1 Cutting Sump Remediation

Nil

DMIRS WMP Petroleum Compliance Brach Online submission & Email

16/03/2018 Update Well Management Plan for care and maintenance regime for all three wells

Nil Submitted


DMIRS Petroleum Environmental Branch

Meeting 07/03/2017 Meeting following submission of Rev 0 of the Red Gully C&M Environment Plan. Amanda Cortez made suggestion for areas of improvement and advised that the assessment would be undertaken within 30 days. MRL were reminded of their commitments and the due date for the remediation og the RGN1 mud sump.

DMIRS to assess EP and OSCP

RFIs received from DMIRS


DMIRS Petroleum Environmental Branch DMIRS Resources Branch - Wells

Meeting 23/02/2018 Discussion in relation to the way forward with the remediation strategy for the cutings sump and evap pond 1 with Arcadis (Ciaran Lavery) acting as a consultant. Also ADD Energy Eduardo Robaina with the well strategy moving forward for RGPF and RGN1. Discussion on the extra monitoring bores for RGN1

Submit C&M EP asap FMP to be reviewed

Ongoing





Status / Resolution

Discussion on the delay of the cuttings sump and evap pond 1 and plan. Discussion on the well monitoring regime and the risk assessment process utilised and forward thinking. Field Management Plan to be revised accordingly

Ensure remediation is expedited

DMIRS Camp Petroleum Environment Branch Email 09/02/2018 Email correspondence with Amanda Cortez in discussion related to septic tanks. Amanda reiterated the importance full remediation as required by the Act with the area backfilled and re-contoured appropriately.

Septic tank remediation required

Septic Tankls removed, soil test came negative further emediated

DMIRS RGPF Petroleum Environment Branch Email 07/02/2018 Email sent to Amanda Cortez DMIRS PEB with justification evidence for the delay in removing liquid from the cuttings sump and Evaporation Pond 1.

No action required

Complete and awaiting feeback from DMIRS if required

DMIRS PL96 Petroleum Environment Branch and Resources Safety

Courtesy advice on Image Resources transporting vehicles over PL96 to George Minto DMIRS PS and Amanda Cortez DMIRS PEB. Advice from PS was to review our MAE’s in case there are further ones to consider. Minto was advised there are no further MAE’s as this has been considered as well as there is little to no risk due to strategies in place.

Review MAEs

MAEs reviewed, Complete

DWER RGPF Licencing Email 31/01/2018 Provided Clint Joseph DWER with Annual Report No action required

Complete

DMIRS RGPF Petroleum Environment Branch Email 31/01/2018 Provided Amanda Cortez DMIRS PEB with Annual Report No action required

Complete


Petroleum Environment Branch Meeting 23/01/2018 Meeting at DMIRS PEB with Amanda Cortez with introduction of Kim Dennison MRL Enviro. Discussion around forward movement with remediation of sump, CA from the DMIRS inspection and way forward with the C&M EP

Ongoing Complete

DMIRS RGPF Petroleum Environment Branch Meeting 16/01/2018 Meeting at DMIRS PEB with Amanda Cortez, Lisa Dumbrell and Brad Jakowyna ICW Vaughn Hinkley, Angus Walker and Matt Collier MRL. Discussion with some supporting information on delaying until mid-March the removal of liquid from Cutting Sump and Evaporation Pond 1 due to costing and safety issues with road access and H2s. DMIRS required information on the supporting evidence to show how this will not be an issue to the environment, but in the interim they are happy for MRL to delay however ensure compliance to all items by the 28th February 2018 with a close out report.

Close-report by 28/2/18

Complete

DFES RGN1 WIA DFES Letter/Email 7/11/2017 Notification to key stakeholders of the intent for Empire Oil & Gas NL to undertake Well intervention activities at the Red Gully Production Facility, located within L18 and L19 and associated PL96, commencing 1st of December 2017.

No action required

Complete

DMIRS RGN1 WIA DMIRS Letter/Email 7/11/2017 Notification to key stakeholders of the intent for Empire Oil & Gas NL to undertake Well intervention activities at the Red Gully Production Facility, located within L18 and L19 and associated PL96, commencing 1st of December 2017.

No action required

Complete





Status / Resolution

Judith Blenkinsop

RGN1 WIA Judith Blenkinsop Letter/Email 7/11/2017 Notification to key stakeholders of the intent for Empire Oil & Gas NL to undertake Well intervention activities at the Red Gully Production Facility, located within L18 and L19 and associated PL96, commencing 1st of December 2017.

No action required

Complete

Phil Yukich RGN1 WIA Phil Yukich Letter/Email 7/11/2017 Notification to key stakeholders of the intent for Empire Oil & Gas NL to undertake Well intervention activities at the Red Gully Production Facility, located within L18 and L19 and associated PL96, commencing 1st of December 2017.

No action required

Complete

Shire of Gingin RGN1 WIA Shire of Gingin Letter/Email 7/11/2017 Notification to key stakeholders of the intent for Empire Oil & Gas NL to undertake Well intervention activities at the Red Gully Production Facility, located within L18 and L19 and associated PL96, commencing 1st of December 2017.

No action required

Complete

Tony Ruse RGN1 WIA Tony Ruse Letter/Email 7/11/2017 Notification to key stakeholders of the intent for Empire Oil & Gas NL to undertake Well intervention activities at the Red Gully Production Facility, located within L18 and L19 and associated PL96, commencing 1st of December 2017.

No action required

Complete

Arthur Dewar RGN1 WIA Arthur Dewar Letter/Email 8/11/2017 Notification to key stakeholders of the intent for Empire Oil & Gas NL to undertake Well intervention activities at the Red Gully Production Facility, located within L18 and L19 and associated PL96, commencing 1st of December 2017. MRLGM Oil & Gas and HSEQ manager provided feedback to landowner due to request for further information by Arthur Dewar; feedback provided, and phone call made by HSEQ manager to discuss queries.

Feedback Complete

Gavin Drew RGN1 WIA Gavin Drew Letter/Email 8/11/2017 Notification to key stakeholders of the intent for Empire Oil & Gas NL to undertake Well intervention activities at the Red Gully Production Facility, located within L18 and L19 and associated PL96, commencing 1st of December 2017.

No action required

Complete

Gingin Football Club

RGN1 WIA Gingin Football Club Letter/Email 13/11/2017 Notification to key stakeholders of the intent for Empire Oil & Gas NL to undertake Well intervention activities at the Red Gully Production Facility, located within L18 and L19 and associated PL96, commencing 1st of December 2017.

No action required

Complete

DMIRS Titles All Petroleum Titles Email 15/09/2017 Notification as titleholder of Empire Oil Company (WA) Ltd entering Voluntary administration

follow up

All EP389 impacted landowners

Black Cormorant

Followed up with phone calls on a number of landholders, and set-up appointments when possible. (phone numbers available)

Phone Calls 11/09/2017 TPC made with relevant stakeholders and advised of the need to catcjh up for a discussion on this matter. Awaiting feedback from stakeholders to arrange meeting agendas.

No action required

Complete

All EP389 impacted landowners (email available)

Black Cormorant

12 Stakeholder were sent emails, as per Landholder Register.

Emails Sent 5/09/2017 Sent through customised notification email, with CEO signed Letter, Attachment A (description of activity) and Attachment B (draft agreement) to each stakeholder to inform them of coming project, seek meeting and contact details.

Follow-up in a week.

Ongoing follow-up with each.

DMIRS EP430 Petroleum Titles Statutory Reporting 4/09/2017 Exploration Permit EP 430 Annual Assessment Report uploaded via PGR

Closed





Status / Resolution

(ref# SOP-EPA-0015)

All EP389 impacted landowners (postal address only)

Black Cormorant

9 Stakeholder were sent postal letters, as per Landholder Register.

Letters Sent 1/09/2017 Sent through customised notification CEO signed letter, Attachment A (description of activity) and Attachment B (draft agreement) to each stakeholder to inform them of coming project, seek meeting and contact details.

Follow-up in a week.

Ongoing follow-up with each.

Whitford Investments / Lot 5439

Black Cormorant

Michael Whitford (0439911895 / [email protected]

Phone Call 28/08/2017 Spoke to Michael to let him know about project. He didn't raise any issues. Michael is based in Perth and happy to meet after he's received and reviewed the information.

Send letter and follow-up for meeting.

Complete

Colbert Farms / Lots 22 & 23

Black Cormorant

Wayne Fewster / PO Box 187, Gingin 6503

Meeting at homestead.

25/08/2017 AW & PA went to Wayne Fewster's home and explained project. He didn't have any major concerns and confirmed his mailing address. He stated that control of weed incursions and fire prevention would be his main requests. We will send him the information and set up meeting to organise an agreement shortly. Wayne was very friendly and helpful in providing some local knowledge.


Complete

Twin Brooks Olives (Deaken and Associates) / Lot 5382

Black Cormorant

Feranando (Twin Brooks Olive site Manager - [email protected] - 0477059282 Josef (Project Manager) - [email protected] -0417952898

Meeting at site offices.

25/08/2017 AW & PA went to the olive farm administration office and spoke to Fernando, the site manager. Fernando was interested in the project and would make sure that the trees and rows would not be damaged, but otherwise didn't seem too concerned. He confirmed we needed to run all of this past his manager in Perth and confirmed contacts. We can set up a meeting subsequently.


Complete

Turnbridge Investments / Lot 5447

Black Cormorant

Arthur Dewar - [email protected]

Phone Call 24/08/2017 Called Arthur to discuss proposed project and organise a meeting. Arthur was very unhappy with the idea of having another seismic go through his property and said he wanted nothing to do with it. He told me that he had nothing against me but that I could 'bugger off'. I explained that this was just a single line of a 2D survey using trucks and geophones and that no up-holes or helicopter activities would be required. Arthur reminded that he had been very much 'burnt' by previous management and had concerns for his water table and didn't want anything to do with Empire anymore. I explained that we needed to meet with him at some stage to explain the survey. He said he wasn't free all week but that I could email him the information. He also enquired about the activities across the road and that it was making some noise ('is it fracking?!'). I informed him that Empire was just doing some maintenance work on the well. Concerns raised. More information and discussion needed with him. Review location of line in proximity to homestead.

Supply more information and conduct further consultation

Ongoing / Conflicted

Landowner / John Kenneth Hall / Lot 403

Black Cormorant

John Hall / 0458 401 600 / [email protected] / PO Box 2367, Clarkson 6030

Meeting at homestead.

24/08/2017 AW & PA went to John's Hall and explained project. He didn't have any concerns and confirmed his mailing address. We will sent him the information and set up meeting to organise an agreement shortly. John was very friendly and helpful in providing some local knowledge.


Complete





Status / Resolution

Shire of Gingin Black Cormorant

Shire Planning and Rates Officer Meeting at Shire Offices

24/08/2017 AW & PA went to the Gingin Shire offices and spoke to 'planning' and 'rates' officer. We briefly explained project and requirements to confirm mailing address for a few of the lots. Rates officer provided all missing addresses. We also mentioned that we would be getting in touch with the Shire when we get close to the operation to make sure they are notified.


Complete

Whitford Investments / Lot 5439

Black Cormorant

Phil George (farm manager, 9655 4031)

Phone Call 23/08/2017 Called Phil George to let him know about upcoming survey. Phil discussed the previous survey conducted by Empire on this land and said that we should speak to the owners (Michael Whitfords 0439911895) before he could get involved. No concerns raised. Send letter with information.

Send letter Closed

Central StockCare / Lot 503

Black Cormorant

Central StockCare / Lynne and Dean Ryan.

Phone Call 23/08/2017 AW Called Central StockCare head offices to discuss proposed project and confirm best contact to provide more information. Spoke to Lyn at reception, who confirmed manager Dean Ryan should be mailed the information. Busy at the moment but a September meeting would be good. No concerns raised. Send letter with information.

Send letter Closed

Gnangara 341 Pty Ltd / Lot 403, Jam Holdings WA Pty Ltd / Lot 404

Black Cormorant

Trandos Farms / Annette and Jim Trandos - [email protected]

Phone Call 23/08/2017 AW Called Trandos Farms head offices to discuss proposed project and confirm best contact to provide more information. Spoke to Annette at reception, who confirmed manager Jim Trandos should be sent the information at: [email protected] No concerns raised. Send letter with information.

Send letter Closed

Landowner / John Kenneth Hall / Lot 403

Black Cormorant

John Hall / 0458 401 600 / [email protected] / PO Box 2367, Clarkson 6030

Phone Call 23/08/2017 PA Called John to discuss proposed project and arrange meeting. John said he was happy to meet at anytime the following day and a visit was scheduled.

Meeting to be held.

Complete

Landowner / Phil Yukich / Lots 501 & 502

Black Cormorant

Phil Yukich / 0407 575 402 Phone Call 23/08/2017 PA Called Phil to discuss proposed project and arrange meeting. Phil said I could send him the required information and follow-up late to set-up a visit/meeting.

Send letter Ongoing / Conflicted

Snowdale Holdings / Lot 32

Black Cormorant

Swan Valley Eggs site personnel Meeting at front gate.

23/08/2017 AW & PA went to the chicken farm front gate and met up with site manager. Send letter and follow-up for meeting.

Send letter Complete

DMIRS EP 440 Petroleum Titles Meeting 22/08/2017 Attended the office of DMP Perth to discuss matters involving partial surrender for EP 440 and associated applications to keep compliant in the work program. JK Notes: Clarify whether we need to retain 3 blocks. We are now only accessing 1 with the reduced seismic scope. Amend request for surrender accordingly. Explain the need to retain this block/s to facilitate access for tails for imaging to EP389 border. Lynn asked what may be learned in 440 by acquiring the tails? What could we learn about 440 by surveying neighbouring 389. This technical info should be part of the formal application letter. Lodge an application for work program exemption for 440 to reduce the commitment from 100km down to 12km tails.

Amend surrender applications submit exemption application via PGR

Complete






Status / Resolution

Success in these applic. will push y2&y3 out to May 2018. If seismic program is delayed. Consult early 2018 (Jan/feb) further extension would need to be strictly by the guidelines re: force majure.

Fewster Property

Black Cormorant

Stuart Fewster Phone Call 17/08/2017 Spoke to Stuart to talk to him about project. He doesn't have any big concerns, just wants to review the information we are to send him by email, as he is based in Kununurra (runs A/Cleaning business up there). He mentioned that his lot is used as a sand mining operation so that would be the main aspect needing management. Send email with information.

Send email Closed

APA (Parmelia) Black Cormorant

Madonna Burns 0408097676 - [email protected]

Phone Call 16/08/2017 Contacted Madonna at APA to inform her of proposal and to ensure any issues with Parmelia were identified early on. She asked for email of proposed project with .shp files and will forward to Parmlia ops/engineering team to review.

Follow up with email and info.

Closed

DBP (DBNGP) Black Cormorant

Neil Parry Phone Call 16/08/2017 Contacted Neil at DBP to inform her of proposal and to ensure any issues with DBNGP were identified early on. She asked for email of proposed project with .shp files and will forward back a S.41 form as well, which is required by RDL.

Follow up with email and info. Prepare S.41 form.

Closed

Swan Valley Eggs

Black Cormorant

9274 2502 (Jeremy) [email protected]

Phone Call 16/08/2017 Called number and spoke to Jeremy. Jeremy didn't seem to want to chat much but recommended I send information about project to the following email: [email protected].

Send email with information

Closed

Red Gully Farm. Black Cormorant

Tony Ruse: [email protected] ph: 0418 942 933

Phone Call 16/08/2017 Spoke Tony to talk to him about project. He doesn't have any big concerns; just wants to review the information we are to send him. Will need to liaise with new farm manager (Ken Wallace) when the time comes. Send Letter - Obtain Farm manager's phone number.

Send letter Closed

Western Power Black Cormorant

tbc Used online contact form for initial

query.

16/08/2017 Fenced areas under power lines, identified as Environmentally Sensitive Area

Follow-up if no response is obtained.

Closed

Colbert Farms Black Cormorant

Wayne Fewster Phone Call 16/08/2017 Spoke to Wayne to talk to him about project. He doesn't have any big concerns, just wants to review the information we are to send him. He confirmed Lot 31 is his cousin (based in Kununurra) He is happy to meet next week in person in Gingin

Follow-Up and set-up meeting date. Prepare letter / email.

Closed

DMIRS (Environment)

Black Cormorant

Amanda Cortez 9222 3776

Phone Call 15/08/2017 No answer - Left Message. Nil Closed

SWLSC (South Land Aboriginal Land Sea Council)

Black Cormorant

Carolyn Fennell (Legal Officer) [email protected] (08) 9358 7400

Phone Call 11/08/2017 Called Carolyn at the SWLSC to see who would be our case officer for the seismic project. She confirmed at this stage it would be her (Justin and Glenn are gone). I explained the project a bit, that we would be crossing a DAA site and wanted early engagement with Yued working group. She was appreciative or early notification and noted that there is a meeting on the 15th Nov. that we should aim to attend. She also recommended I seek advice from DAA relating to potential S.18 triggers.

Sent email with info/scope Organise to attend 15th November meeting.

Closed





Status / Resolution

I need to send her an email with more information on the project details.

DMIRS (Environment)

Black Cormorant

Stand Bowers (DMIRS) / Brad Phone Call 11/08/2017 Contacted DMIRS to confirm who would be our case manager since Corrie Watts has left. I gave Stan an overview of project and explained it was part of Empire's exploration portfolio. Stan confirmed case officers for this would be Amanda Cortez and Lisa Dumbrell (back-up). Call Amanda Cortez and organise a meeting for project update and approvals scoping.

Arrange meeting

Meeting Held

Red Gully Farm neighbour

RG Wellhead Compressi

on

Arthur Dewar +61 417931654 / 08 95754044

Phone call 9/08/2017 Followed up call from 7/8/2017. Message left only. Advised gas smell confirmed as originating from APA who are commissioning an odourising plant.

No further action

Closed

DMIRS EP 440 Petroleum Titles Email 8/08/2017 Email from Lara (DMIRS): I would like to organise a meeting with yourself and Pierre to discuss the applications for EP 440 (stp-epe-0034 & stp-epx-0054) in lieu of the Black Cormorant 2D Seismic Survey project being withdrawn/altered. I would like to schedule it for next week if possible – the DMP attendees will be myself, Alyssa Carstairs and Nina Triche from Resources, is there a day that suits you best? I anticipate that there will be other meetings scheduled as we go for the purposes of the Black Cormorant 2D Seismic Survey project, EP 389 and Empire’s overview moving forward, however let’s get together and discuss EP 440 in the first instance.

Attend meeting

Closed

Meeting 29/08/2017 JK & PA attended meeting on 29/08/2017 No further action

Closed

DMIRS EP 440 Petroleum Titles Email 8/08/2017 Email from Empire for some clarification to assist: Empire will only be acquiring seismic in EP 389. We will be resubmitting the Application to acquire the EP 389 data by October. We note that EP 389 has not yet been renewed following our Application to Renew. The Renewal Application was submitted by Empire in January 2017 and understand the application is still progressing internally in the DMP. We would appreciate this permit being Renewed asap, as we are well advance on planning the EP 389 Survey. Regarding EP 440 Empire have accessed that the prospectively of this permit is very low. Additionally, the permit is largely covered by national park and reserves making seismic acquisition not only unpopular but logistically very difficult. The Permit has also had a fraccing ban/ moratorium imposed on it recently. We have requested a substantial surrender/relinquishment of the permit but we would like to retain the three most eastern blocks as per our latest application for EP 440. This is required because the tails of the 2D lines proposed to be acquired in EP 389 will extend into EP 440 in order to achieve full fold imaging our target leads as identified in EP 389. So, by retaining the three eastern graticular blocks of EP 440 as requested , will facilitate Empire being able to acquire

None Closed





Status / Resolution

the EP 389 2D Black Cormorant survey in a more timely manner. Would like to acquire the EP 389 data in March/April 2018. We have just appointed a new CEO and I will not be able to attend next week but Jade will organise a meeting to discuss EP 440 and what we are seeking and what you may be requiring.



on

Arthur Dewar +61 417931654 / 08 95754044

Phone call 7/08/2017 Followed up call from 3/8/2017. Advised Arthur no signs of gas on gas detector when PIC attended connection. Empire will monitor and perform a soapy water test over the next few weeks. Arthur advised gas smell from Wannamal Rd to Southern truck bay on 3/8/17 @ 18:00 hrs.

RGPF- PIC to examine gas smell at DBPL connection

closed

DMIRS Exploration Petroleum Titles email 4/08/2017 Email to Milton (Empire) from Chris Ferrinda My apologies for not responding earlier. If it suits you and others at Empire, I will book a meeting time for Tuesday 19 September at 9:00am. I will go through the suite of Empire exploration permit work programs and pending applications and, with compliance in mind, flag any matters I believe need to be addressed prior to that date if required.

attend meeting

open

DMIRS EP368 Petroleum Titles Statutory Reporting 3/08/2017 Exploration Permit EP 368 Annual Assessment Report uploaded via PGR (ref# SOP-EPA-0014 )

Closed

Red Gully Farm owner (Lot 5448)


on

Tony Ruse: [email protected] ph: 0418 942 933

Phone call 3/08/2017 Advised of Wellhead Compression scope and schedule. (10 weeks plus rain) All ok. Tony is waiting on new organisation and contact chart from Angus EO to issue organisation chart and contacts to Tony

Issue requested documents

open



on

Arthur Dewar +61 417931654 / 08 95754044

Phone call 3/08/2017 Advised of Wellhead Compression scope and schedule. Discussed noise mitigation activities, housing, survey etc. Generally happy to receive call. Notified EO of smell of gas at end of Wannamal Rd.

RGPF- PIC to examine gas smell at DBPL connection

closed

Landholder LD-1

Lockyer Deep-1

Sally & Steve Brindal [email protected] 0427275014 3983 Burma Road, Mount Horner WA 6524

Email from MS 2/08/2017 Email from Milton Schmedje (Empire Exploration Manager) to Sally and Steve Brindal: To follow on from the Land Access guide lines and supporting information on Lockyer Deedp-1 that I recently sent you. I would like to let you know Allan Watts will be in contact to have a chat at a convenient time, about Lockyer Deep-1 and potential land access getting the negotiation process started. Allan has the coordinates for where this this vertical well will be drilled subject to your agreement. It is as per the map that I forwarded previously. This location appears to be an optimal site with good access and minimal interference. Also there have been some changes at Empire and we have a new CEO, Angus Walker. I have known Angus for some time prior to Empire and he is an honest and straight forward guy. We are currently lining up the funding for Lockyer Deep-1 and I know that when this is put to bed, Angus would like to come up with me and meet with you personally and take a look at where we are planning to drill. I

N/A Satisfactory





Status / Resolution

suggest we will do this at a convenient time and once we are a little further progressed on your expectations re the land access negotiation. We have taken on board your concern about acquiring seismic and can confirm Empire is not planning to undertake any seismic in your area. We have told the government/regulator this. We have decided not to undertake seismic as we do not wish to alienate the land owners as many have serious issues/concerns about seismic. We respect this. It is paramount to us to maintain a really good and transparent, working relationship with land holders. We will at all time respect the land holders and work with them to ensure they are happy with our operations and always work to a win-win outcome.

DMIRS Black Cormorant

Petroleum Titles Email from JK 2/08/2017 RE: Request for the withdrawal of survey applications relating to the Black Cormorant 2D seismic survey In March 2017, applications were lodged on behalf of Empire Oil Company (WA) Ltd with regard to the company’s proposed Black Cormorant 2D Seismic Survey. The applications are referenced below; SOP‐SYA‐0162 – EP 389 SOP‐SYA‐0163 – EP 432 SOP‐SYA‐0164 – EP 440 SOP‐SYA‐0165 – L 18 SOP‐SYA‐0166 – L 19 STP‐AAA‐0033 – EP 494 STP‐AAA‐0034 – EP 447 Since the time of initial application, some changes have been made to the scope of the project including a reduction in the area to be surveyed. As a result of these changes, the survey applications in their current form, are no longer in order for assessment and we formally request they be withdrawn. We will be in the position to submit applications reflecting the new project scope in the coming weeks.

lodge revised applications - meet with DMIRS by end of August

Closed

DMIRS Exploration Petroleum Titles Email 1/08/2017 Hi Chris, have you had any success in trying to line up a meeting for Empire to come in and discuss with your team the various permit work program, where we are at and what we are planning to do in each permit. As mentioned can we pick a time somewhere that suites you and the team in the last two weeks of September , as this will be after the Good oil and the Open Day.

Follow up email

closed


Petroleum Titles Email from DMIRS 1/08/2017 Email to Jade Koellner (Empire) from Lara Haenga With regards to Empire’s intention to reduce the scope for the Black Cormorant 2D Seismic Survey project and your request to discuss the matter, I would first request that you withdraw the existing Black Cormorant 2D Seismic Survey project applications. The applications are no longer in order for assessment in their current form, as per your advice that you will be significantly reducing the scope of the project. Accordingly, would you please make request in writing to the Executive Director with attention to Senior Titles Officer Lara Haenga via

N/A closed





Status / Resolution

[email protected] for the withdrawal of following applications: SOP-SYA-0162 – EP 389 SOP-SYA-0163 – EP 432 SOP-SYA-0164 – EP 440 SOP-SYA-0165 – L 18 SOP-SYA-0166 – L 19 STP-AAA-0033 – EP 494 STP-AAA-0034 – EP 447 I will set up a meeting with relevant DMIRS officers to meet with Empire representatives between 28th Aug – 31st Aug 2017 and advise accordingly When Empire is in order to make application (resubmit) to undertake the Black Cormorant 2D Seismic Survey project or any other project, we are here to assist with the process. Please do not hesitate to contact myself should further clarification be required and your early attention to this matter is appreciated.


Petroleum Titles Email to Regulator 31/07/2017 Email from Jade Koellner (Empire) to Alyssa, There has been a need to reduce the scope for the Black Cormorant Survey. I’m working to revise the application documents and was hoping to discuss this with you. Pierre is finalising the EP and we are looking to schedule a meeting in August with DMIRS Titles and DMIRS Environment to provide an update and also to confirm S. 15 and self-referral. requirements. Can you confirm if the week 28th Aug – 31st Aug will work for you?

follow up on meeting

Complete

DMIRS Exploration Petroleum Titles Email 25/07/2017 Email to Chris Any time post good oil/DMP open day should work for a round up on the Empire work programs and permits. Week two of is ideal. If Alyssa can provide some back ground on her queries on Black Cormorant more than happy to drop in next week. Also please note we have requested a hold on the proposed Black Cormorant 2D Survey as the going on the ground (access ) is very challenging to say the least. We will resubmit a reduced Black Cormorant Survey by early October. This will focus on EP 389 only. We have just engaged Alan Watt’s to start access discussion in earnest for the EP 389 2D and Lockyer Deep. PS we have a new CEO now. A changing world in the oil business these days.

confirm / attend meeting

closed


Complete

DMIRS Exploration Petroleum Titles Email 7/07/2017 Email to Alyssa I realise there is a lot going on at present but as we have not been able to confirm at this stage the meeting I proposed some time back for late August I have had to allocate that time. I am now tied up assisting farminee’s on their DD in the August window, so I suggest the DMP

Follow up email

closed






Status / Resolution

meeting to discuss Empires Exploration Permits now take place in September (likely after Good Oil/DMP open day ?). Appreciate if you can confirm to Jade the DMP’s availability in September so we can line up the meeting as requested run through each permit. Also we do need to get feedback asap on the status of the EP 389 Renewal, as we are now engaging in access discussions with land owners (or will be next month). I think Lynn mention it may be with a group outside the titles section but appreciate an update if you can.

Landholder LD-1

Lockyer Deep-1


Email MS to Landholder

5/07/2017 Email to Sally and Steve Brindal from Milton (Empire): Attached are some documents for you to have a look at regarding Land Access Agreement that we will talk on more. The Land Agreement is a draft only but want to get you these give you plenty of time. One thing that comes to mind that could be an issue is potential noise from the rig. It is probably only a 20 day well or so, but it does go 24 hours, so we need to make sure that you are not inconvenienced.

arrange meeting in August

Ongoing / Satisfactory

Landholder LD-1

Lockyer Deep-1



3/07/2017 Email to Sally Brindal from Milton (Empire): Empire will use Pierre (copied) to assist with the land access agreement. We will get a draft version of the standard Agreement for your consideration hopefully over the coming week or so. Then we will come up at suitable time and have another chat. We will bring a GPS up show you both where we are think of siting the well.

follow up with draft/proforma agreement

Complete

DMIRS Exploration Petroleum Titles email 3/07/2017 Email to Bev, Lynn and Chris: It’s a way of yet but lets try to catch up the week of August 21 for a show and tell of where Empire is at on all of it operated permit ( if that works). Or else the week after. Might be best if you choose a day and time as we can work around your schedule. I would just like to get it lock in. PS is any word on the EP 389 Renewal as are starting to progress the planning of the 2D in EP 389 and spending money. FYI the current Black Cormorant 2D survey is on hold with the DMP at our request, as we plan to have new documents in by October 2017. This will be quite different from what is on hold in your system at present and will focus solely on EP 389. Will explain more at our meeting. We are planning to acquire the EP 389 2D seismic in March/April 2018, so need to get all the application and plans in to the DMP in by October 2017 to meet that time frame.

follow up email

closed

DMIRS Exploration Petroleum Titles email 3/07/2017 Email to Milton (Empire) from Beverley Bower Chris is on leave for a couple of weeks, but Alyssa will be able to help you with the status of EP 389 renewal and setting up the meeting. Regards,

Follow up with Alyssa

closed

Landholder NED-1

Nth Erregulla Deep-1

CHERIE & STU SMART 0428281346 / 08 99281006 [email protected] S&C Smart Pty Ltd “Erregulla Plains” Farmers & Graziers 23245 Midlands Rd, Mingenew WA 6522


29/06/2017 Email to Cherie Smart from Milton (Empire): I hope you are all good out there and you get a good season and prices. I just wanted to get back and let you know that we will probably drill at Lockyer Deep-1 over around the Brindals first. In the event we got a discovery then we would pick up again on talking about North Erregulla Deep-1 and possible access etc. Please note this is a technical decision as we think Lockyer Deep a more definitive test of the trend. I hope we get a

N/A Complete





Status / Resolution

chance to have that discussion, but it is exploration, so success rates are typically only around 20% on for onshore drilling. Also we are drilling this well as a conventional well, and are not considering Fraccing (at all), which I know has a lot of people concerned. Also, I want to confirm my view that given a few land owners have expressed concerns about seismic data being acquired over there properties and some bad experience experiences in the past by some past operators, that I am recommending that no seismic be undertaken in the area by Empire at this point in time. I have to have this conversation with the Department (DMP). I know that when Origin where up that way some years back and yourself and Stu had issues with seismic and possible adverse effect on the ground (compaction). I want to keep land holders on side, work with them and not get them offside. It’s their land.


Complete


Complete

DMIRS RGN-1 Petroleum reporting Statutory Reporting 20/06/2017 Well Activity Report - RGN-1 Workover uploaded via PGR (ref#SOP-EPA-0010)

Complete

DMIRS RGPF DMIRS Meeting 16/06/2017 Quarterly stakeholder meeting to align expectations between stakeholders Nil Closed


Complete

Wayne Fewster - Landholder EP 389

Black Cormorant

Wayne Fewster 0428754017 [email protected]

Phoned back PA following message left to his mailbox.

29/05/2017 PA spoke to Wayne and explained that Empire are planning a 2D seismic in the region for the first half of 2018 and wanted to brief him of the proposal. PA explained that it would be 2D with trucks and that a couple of the lines may run through his property, with other lines in the properties North and East of his. Wayne seemed familiar with the process and said that a similar survey had been done in their area in past with trucks and fence removal/re-instatement. He seemed fine with it but just said that we could get in touch to plan a meeting when we went back up there in the future to review the exact scope and discuss impacts to his operations. I told him that we could tee something up in July.

Send him final EP389 map scope once finalised and organise a meeting in July.


DMIRS EP389 Petroleum Titles Statutory Reporting 26/05/2017 Exploration Permit EP 389 Annual Assessment Report uploaded via PGR

Complete





Status / Resolution

(ref# SOP-EPA-0007 )

DMP Environment

Evap pond PFW

removal

Virginia Simms Email notification 25/05/2017 As per the email correspondence you received from Stuart Webster, Acting General Manager Resources, Petroleum Division on 23 May 2017, DMP notes that water removal from the Red Gully evaporation pond may be undertaken to ensure that Empire Oil and Gas NL remains compliant with Section 37 of the Petroleum Pipelines Act 1969. The proposed activity must be undertaken in accordance with this letter of consent until such time that a revised Environment Plan is approved by DMP under the Petroleum Pipelines (Environment) Regulations 2012 to include the ongoing management of produced water at the facility; or no longer than 31 August 2017 (whichever occurs first). I advise that this consent has been issued under regulation 7 of the aforementioned Regulations.

Return email notification. JM to progress the PFW removal from the Evaporation pond


DMP Environment

Meeting Request

Corrie Watts Jacqui Middleton

Email notification 22/05/2017 Email from Vaughn Hinkley (Empire) to DMP) 1. Organise a date for everyone to catch up this week about the License

update (George Minto, yourselves and Stuart Webb) 2. Discuss the possibility for a light extension beyond the 14th June 2017

for the Care and Maintenance EP (tight timelines with the current EP upgrade, gathering RFI for the 26t May to return to your office, develop a corrective action plan for return to your office for the recent inspection report and revise/update the OSCP)

3. Establishing if the 9th of June 2017 is a good date for the quarterly catch up meeting involving all DMP stakeholders

4. Any news from the review of the PFW removal from the evaporation Pond procedures that were submitted last week

Wait for contact if any issues from DMP


DMP Environment

Information follow up

Virginia Simms Email notification 22/05/2017 Email to Virginia Simms from Vaughn Hinkley (Empire) Good afternoon Virginia, I hope this email finds you well. My name is Vaughn Hinkley and I am a Senior HSEQ Advisor with Empire Oil and Gas (NL). I am just touching base in relation to the above mentioned topic, to establish if there is anything that can assist you with, and if not appoint the appropriate resources to do so. Our Chief Executive Officer is currently out of the country on business, so I am following up on his behalf to ensure any expedient information can be forwarded to your office for your assistance. If there are any questions, comments or concerns please don’t hesitate to contact me forthwith and will be happy to help.



DMP Environment

Follow up on

submission of PFW

TRFR from Evaporatio

n Pond request

Virginia Simms Email notification 22/05/2017 RESPONSE TO VIRGINIA SIMMS IN RELATION TO EMAIL DETAILS ON WATER TRANSFER PROCEDURE Explanation that Empire request to transfer water from the evaporation pond which is very close to the 300mm freeboard threshold. Rain is anticipated over the current period (much rainfall over the weekend) as well as the time in which the review and approval for the new EP when submitted (soon). Empire are extremely concerned that there may be potential the freeboard will be at risk with the impending rains for this time of year.







Status / Resolution

DMP Environment

RGPF Virginia Simms Email response 22/05/2017 RESPONSE TO VAUGNH HINKLEY IN RELATION TO EMAIL DETAILS ON WATER TRANSFER PROCEDURE Direction to Empire that:

If this is an emergency situation, a letter to the Executive Director Petroleum Division can be submitted outlining the extent of the emergency, specifying a required timeframe for the removal of the water for disposal by Toxfree Australian Pty Ltd and the need for approval on the grounds of reducing environmental impacts/harm. The Executive Director Petroleum can grant emergency approval for the removal of water in accord with the relevant Act

If the temporary removal of formation water is not posing an immediate or imminent environmental impact, then a bridging document is required to be submitted via DMP’s EARS online registration process referencing the current EP and relevant OSCP documents.

The large pdf document entitled “ Formation Water Temporary Disposal Procedure” (dated 18 May 2017) Empire submitted by email on 18 May 2017 to Karen Caple, A/Executive Director Environment, is not a bridging document and cannot be approved as submitted. It does contain some information which will be relevant to the bridging document.

DMP’s current EP guidelines contain information on bridging document requirements, see the website for more information on these guidelines. http://www.dmp.wa.gov.au/Documents/ENV-PEB-177.pdf

The bridging document should contain only that information relevant to the proposed activity of removing the formation water and setting a timeframe for the activity to be completed by (for example, by 31 August – end of winter period), including currently proposed and/or recent water content results.

Corrie Watts, Environmental Officer will contact you in writing to discuss the specifics of the details of the email and to touch base with you on the EP requirements so as to ensure there is an agreed understanding of what documents are to be submitted to DMP for a considered and timely environmental assessment

DMP looks forward to receiving the new EP to be submitted by 1 June 2017

Make submission to DMP

DMP Environment

Information follow up

PEB Email notification 22/05/2017 Corrie Watts email with responses to Empire requests: 1. “Organise a date for everyone to catch up this week about the License

update (George Minto, yourselves and Stuart Webb)” Corrie will email Stuart and George and try and pin them down for a date/time to meet. Jacqui is away this week, but I can see if the others are free. I may also invite someone from titles as well if that’s ok?”

2. “Discuss the possibility for a light extension beyond the 14th June 2017 for the Care and Maintenance EP (tight timelines with the current EP



http://www.dmp.wa.gov.au/Documents/ENV-PEB-177.pdf

http://www.dmp.wa.gov.au/Documents/ENV-PEB-177.pdf





Status / Resolution

upgrade, gathering RFI for the 26th May to return to your office, develop a corrective action plan for return to your office for the recent inspection report and revise/update the OSCP);” This is accepted. Thank you thank you. I was thinking about 14th July, as we will have comments back from you by then and can propagate the C&M with the information if required?

3. “Establishing if the 9th of June 2017 is a good date for the quarterly catch up meeting involving all DMP stakeholders; This would be suitable if it was a morning catch up” Looking around 10ish if ok?

The submission on the PFW removal from the evaporation Pond procedures that were submitted last week are being reviewed by Virginia has this and will be in touch this afternoon to clarify a few things. Received and reviewing.

DMIRS RGN1 PEB Email 22/05/2017 Email from Empire requesting a meeting and the possibility for an extension to the due date for the RGN1 EP from 14/06/2017 to 14/07/2016. No response was received from DMP PEB.

Empire to submit by 30/6/2017

Closed

DMP Environment / Safety and wells

Meeting Request

George Minto Corrie Watts Jacqui Middleton Stuart Webster

Email notification 19/05/2017 Further to his conversations with the DMP, Ken Aitken has asked if it would be possible to schedule a meeting upon his return from overseas during the week of the 6th of June (Monday the 5th is a public holiday, WA Day). Vaughn Hinkley, Steve McCollin and Milton Schmedje will also be in attendance and we would be pleased to come to your office in East Perth. Our team is available after 1 p.m. on Tuesday the 6th or after 12 noon on Wednesday the 7th, but otherwise they are flexible and can accommodate your schedules.



DMP Environment

Fluid trfr RGPF

Karen Capel Email and procedure

18/05/2017 Forwarded procedure request on behalf of Empire Oil and Gas (NL), as a result of a discussion I had with our Case Officers from the DMP Environmental Team. We have been advised that due to our current EP not covering these specific activities, and this particular request is outside of our existing operating parameters, this will need to be corresponded to you as the Senior Manager of the Environmental Division to make a decision for a way forward.

Wait for contact if any issues from DMP Environmental team


DMIRS RGPF DMIRS Phone & email 17/05/2017 RGPF discussion on EP, OSCP, Risk Assessment requirements, supporting documentation and License update. OSCP requirements for RGN1 also discussed. Minutes of meeting to be forwarded Organise a liaison meeting with all DMIRS stakeholders and EOG Minutes forwarded via email Meeting to be organised with all relevant stakeholders

Forward minutes

Landholder LD-1

Lockyer Deep-1


Visit to Landholder Property

11/05/2017 MS / KA travelled to landholders property at 3983 Burma Road, Mount Horner WA 6525 to make introductions

Email late June Updat DMP if there are any issues / changes.

complete





Status / Resolution

Landholder NED-1



Visit to Landholder Property

11/05/2017 MS / KA travelled to landholder’s property at 23245 Midlands Rd, Mingenew WA 6522 to make introductions

Email late June Updat DMP if there are any issues / changes.

complete

DMP Environment

CSE RGPF Corrie Watts Jacqui Middleton

TPC - Message left 11/05/2017 TPC made to both parties but unavailable. Advised of the valve greasing job on site and outlined the reasoning behind the work and to contact Vaughn Hinkley for any further details if required.

Wait for contact if any issues from DMP PEB


DMP Environment

RGPF EP Corrie Watts Jacqui Middleton

Visit to office 10/05/2017 Attended the office of DMP Perth to discuss matters involving the recent submission of bridging EP for the Evaporation Pond works on site. Due to recent correspondence (letter from the DMP stipulating that a review of the current EP and resubmission needs to be moved forward and submitted by the 1st June 2017. The engagement also covered the stakeholder relationship between the two parties and the significance of moving forward with a successful resubmission of an updated EP so that future works can continue. This was successful with a follow up email highlighting the minutes of the meeting.

Further correspondence will continue with the case officers


Landholder LD-1

Lockyer Deep-1


Email 2/05/2017 MS initiated contact with landholders of LD-1 proposed well site in EP368. discussed the possibility of a meeting. Landholders agreed.

MS / KA to visit

Complete

Landholder NED-1



Email 2/05/2017 MS initiated contact with landholders of NED-1 proposed well site in EP368. discussed the possibility of a meeting. Landholders agreed.

MS / KA to visit

Complete

Tony Ruse RGN1 wellsite &

access road

Tony Ruse Phone 1/05/2017 KW called Tony to ascertain what has to be done to remediate the RGN access road. TR enquired about his last invoice which has not been paid. KW advised that he resubmit.

Ongoing. TR to advise quote from his contractor.


DMIRS RGN-1 Yasinta Situmorang [email protected]

email 26/04/2017 Address discrepancies in the Red Gully North 1 WCR data and provide Outstanding Data ref# S21671

provide data

Complete





Status / Resolution

DPAW Black Cormorant

Dan Coffey Phone Call 6/04/2017 PA Called Dan Coffey from DPAW, to canvas proposed process for consulting with DPAW regarding proposed survey. Following process was confirmed:

- S.15 for access to reserves will be required. Once EP is lodged these can be finalised.

Once EP is drafted, we can set-up meeting with DPAW and DMP to discuss additional management measures and comments required for the survey and access to park

Key concerns are likely to be hygiene related (dieback - dry soil, cleaning, controls, fire and access points to reserves).

Dan also confirmed that self-referral to EP was a prudent approach (due to triggers) and that they would want to see a completed EP containing DPAW input for efficient assessment.

Follow-up with Email memo and meeting request in late April


DMP Black Cormorant

DMP Titles Email Lodgement 23/03/2017 JK lodge Survey Applications for the proposed BC survey with DMP, following adequate consultation with DMP titles branch (Lara Haenga provide input to queries on 20/03/2016). PA also spoke to Lara Haenga about timing of following submission requirements (EP and SMS) which still needed some significant work. Lare noted they could hold onto the application for some time. We just need to keep them updated.

Follow-up with Email memo and meeting request in late April


DMP EP432 Petroleum Titles (Senior Titles Officer / Senior Technical Officer)

Statutory Reporting 14/03/2017 Submission of documents:

Annual Assessment Report EP 432 Permit Year 6 for the missing period 11 April 2010 to 11 April 2014

Annual Assessment Report EP 454 Permit Year 6 for the missing period 26 February 2012 to 25 May 2014

For each of the above Permits, a report for the first part of the Permit Year 6 was lodged on 25 February 2015. However, upon my review of these reports, I noted key information was missing. For example, the section on expenditure was left incomplete. I have therefore, compiled the original submission and additional information into Empire’s updated report format. For your convenience, the initial reports and email transmittal have also been included, as an enclosure. I trust the attached submission completes the compliance reporting for the entire PY6 for EP 454 & EP 432.

N/A Complete

DMP EP454 Petroleum Titles (Senior Titles Officer / Senior Technical Officer)

Statutory Reporting 14/03/2017 Submission of documents:

Annual Assessment Report EP 432 Permit Year 6 for the missing period 11 April 2010 to 11 April 2014

Annual Assessment Report EP 454 Permit Year 6 for the missing period 26 February 2012 to 25 May 2014

For each of the above Permits, a report for the first part of the Permit Year 6 was lodged on 25 February 2015. However, upon my review of these reports, I noted key information was missing. For example, the section on expenditure was left incomplete. I have therefore, compiled the original submission and additional information into Empire’s updated report format. For your convenience, the initial reports and email transmittal

N/A Complete





Status / Resolution

have also been included, as an enclosure. I trust the attached submission completes the compliance reporting for the entire PY6 for EP 454 & EP 432.

Gingin ER RGN-1 well test

Phil Barret. Community Emergency Response Manager (0408943576) [email protected]

Phone 20/01/2017 KW sent an email to PB acknowledging that the DFES reps had twice been to site recently. PB called back saying they were DFES but also concerned local’s persons. Suggested that we make contact with DFES comms centre (1800 198 140) to let them know of our operations in advance of night time flaring. KW encouraged PB to visit the wellsite. KW agreed to hold more water onsite despite not actually required under our exemption - this will placate local concerns and help community liaison. KW to call DFES communications - done. KW to advise WSM of possible DFES visit - done. KW to ask WSM to hold more water (5000 litre) at RGN-1 - done

KW to follow up fire management requirements


DFES communications

RGN-1 well test

James of DFES Communication Centre

Phone 20/01/2017 Following discussions with Phil Barret of Gingin DFES KW called the DFES comms centre in Perth (1800 198 140) and explained our operations during testing. We committed to calling this number at 1900 hr if we intend to flare overnight. We are logged in their database as an operation that has an exemption but may flare at night, so any 000 calls can be handled without mobilising the fire trucks. No further action except when flaring at night in which case the WSM must call the DFES comms line. KW advise WSM by email of this need.

Notify DFES when flaring at night


DMP Petroleum RGN1 workover

Stuart Webster Phone call 20/01/2017 KW & KA talked to SW wrt comingling Upper D and C Sands for combined test. SW was fine - wanted an email. Done

KW to send email to SW - done

Closed

Tony Ruse RGN1 workover

Tony Ruse Phone / email 19/01/2017 Tony called to know what was happening. Said sheep might be in our paddock next week.

Ongoing. KW to update TR by 24/1.


Gingin ER RGN-1 well test

Phil Barret. Community Emergency Response Manager (0408943576) [email protected]

Email 9/01/2017 KW sent an email to PB to advise that workover well test is to commence this week.

NA Ongoing / Satisfactory

RGN-1 neighbours

RGN-1 well test

Arthur Dewar Gavin Drew Phil Yuckich

Phone 9/01/2017 KW called all three separately. All are fine with well testing starting on Wednesday. Arthur asked for a call when test is complete.

KW to call Arthur


DMP Black Cormorant

Corrie Watts Stan Bowes

Meeting 14/12/2016 PA and AK met with DMP environment to provide initial overview of proposed Black Cormorant 2D SS. Discussion relating to approval timelines, S.15 consent and OEPA referral process were discussed. Recommendation to keep full-fold acquisition outside of parks and reserves was discussed, as it would impact approval timeframes. Even if low impact, self-referral to OEPA was still recommended as it prevents proponents making a referral later in the process and slowing down process.

Follow-up with draft/final EP submission in Feb 2016



Tony Ruse Phone / email 9/12/2016 KW phoned Tony to advise wrt workover suspension. Tony has no issues but mentioned that he will be shearing early in the new year. Traffic

Complete Ongoing / Satisfactory





Status / Resolution

management will be needed. Also asked where payment of his invoice is. KW to check with accounts. KW to send email to Tony confirming above.


Stuart Webster Phone call / email 8/12/2016 KW talked with SW wrt delay of BOP test. No concerns. KW to send an email.

Complete Closed


Stuart Webster Phone call / email 8/12/2016 KW talked with SW wrt temporary suspension of RGN-1 workover. No concerns. Empire to send letter with plan and drawing.

Complete Closed


George Minto Phone call 30/11/2016 KW received a phone call from GM wrt the fire incident 00092 at RGN-1. KW requested that GM questions be sent by email. 1/12: KW received an email from GM with questions. 5/12: KW sent answers to GM

Submission of updated contractor bridging documents


Farm neighbour RGN1 workover

Peter Johnson (Red Gully Farm Hand)

Letter and phone calls

11/11/2016 In a phone call Tony requested a letter confirming that EGO is not planning to frack the RGN-1 well. This was prepared and signed by KA then mailed to Tony. In addition, Tony advised that Peter Johnson his farm manager had had a heart attack and passed away. Condolences were expressed.

KW sent a letter from KA

Closed


Phil Yukich Phone Call 25/10/2016 KW called PY and advised that work would recommence in November. PY was ok with this. He said that in April he had a concern that there would be a lot of noise, but he watched us from his land through binoculars and was not concerned. He said that the current Empire is much better to work with than previous management.

KW to send a letter from KA



Judith Blenkinsop Visit 25/10/2016 KW and NB visited JB at her house. She was very welcoming, and we talked amicably for a while. KW updated her with our plans to perform a workover, but she admitted that she would hear us due to the noise of her chickens.




Peter Johnson (Red Gully Farm Hand)

Visit 25/10/2016 KW and NB were departing Red Gully Farm and met PJ. We stopped and chatted for a while. He is happy with the current situation. He told us they would be shearing sheep in first week of Nov but no conflict.




Arthur Dewar Phone Call 24/10/2016 KW called AD and advised that work would recommence in November. AD was ok with this. He said that he was unhappy about how Tony Ruse firebreak had been cut last year and wanted EGO to ensure no damage was caused. KW advised that EGO would not be cutting fire breaks for TR. Secondly, he commented that the remediation of the land over the pipeline from the RGPF to the DBP was poor. KW advised that he pass on the info to production.



Westpork RGN1 workover

Neil Ferguson Email 24/10/2016 KW email to advise start of operations and to exercise traffic care in the area.

None Closed / Satisfactory


Gavin & Sheila Drew / 0427 680 955

Phone Call 21/10/2016 KW called Gavin to let him know more about the upcoming workover program and to let him know the operations would be commencing in early November. He had no issues and said we could drop by to visit him anytime. Gavin was in a hospital as his wife was ill. KW advised a letter would follow.



Gingin ER RGND Phil Barret is Paul Postma's deputy while he is on sick leave. Community Emergency Response Manager

Phone call 21/10/2016 Contacted the mobile number and Bill Barron (?) answered. Very bad line. KW advised that RGN-1 workover is planned. Confirmed to send an email to advise plan and timing. They may want to meet up.

Send email Ongoing / Satisfactory





Status / Resolution

(0408943576) [email protected]

KW to email with update. 24 Oct: KW sent email to CESM address advising planned ops.


Arthur Dewar Phone Call 21/10/2016 KW called but no answer - left message that we shall phone back on Monday.

KW to call 24/10/16



George Minto Meeting 7/10/2016 HSE Quarterly Meeting which included RGN1 Planned Workover & Testing Campaign Nov 2016

Submission of updated contractor bridging documents



Stuart Webster Phone 6/10/2016 Short phone call confirming DMP receipt of the WMP. Ongoing Ongoing / Satisfactory

Gingin Shire RGN1 workover

Jeremy Edwards, Karen Oakley (PA)

Meeting 5/10/2016 KW & JM met Jeremy Edwards (Gingin Shire President) and presented a verbal update on progress at RGPF and RGN. He expressed his appreciation of the information.



Tony Ruse Meeting 5/10/2016 KA & KW met with TR and agreed terms for extension to land access agreement. Letter of agreement signed by all parties


Gingin Shire RGN1 workover

Jeremy Edwards, Karen Oakley (PA)

Emails 24/09/2016 Emails traded and finally agreed KW to meet with JE to provide update. 5th Oct at 1000

Complete Complete

DFES Gingin RGN1 workover

Paul Postma Phone 24/09/2016 Phoned Paul Postma to advise update and arrange meeting. He is away until 10 Oct. Message left on phone. Karen Oakley was copied on email.

KW to contact PP mid-October



Tony Ruse Phone calls 22/09/2016 After several emails Tony has agreed to the resolution of all old emails. Now we are working to close out the agreement for the next phase.

Draft letter sent - awaiting TR to respond.



Stuart Webster plus 3 Meeting at DMP 8/09/2016 KA & KW met with DMP to present outline plans for RGN-1 workover. Complete Complete


Tony Ruse Phone calls 30/08/2016 Several phone calls ending with agreement to grade access road on 1/9. Also to provide 2 days of Anspach time for farm work. Also to send a draft extension letter to Tony for review. 8 sept: KW agreed verbally with TR that EGO would pay him 3 days of $ equal to Anspach grader charges. Also agreed in principle the 1-day cost per week of operations for workover in November.

Kw to send draft letter and authorise Anspach to perform work



Tony Ruse Meeting 24/08/2016 Meeting with KA. KW & JM and Tony Ruse to establish process for access agreement for Nov 2016 workover. Discussed ongoing operational access and need to remove fluid from RGN-1 sump.

KW to send planned activity email to TR.


DMP Safety RGPF Joanna Wong, George Minto, Keiran Galvin

Regular Update Meeting

29/07/2016 JM, SM, YL, DT, PA: Update on draft RGPF SC/SMS submission (response notes provided) and operations and heads-up. DMP expressed interested in auditing during upcoming shut-down and pigging ops. See DMP action tracker X:\HSEQ (CORPORATE)\1. EMPIRE HSEQ MS\10. Communications\1. Regulatory Meetings\DMP Meetings

Complete actions in action tracker

See DMP action tracker





Status / Resolution

DMP Safety RGN1 C&T George Minto, Keiran Galvin Regulatory Safety Audit

3/05/2016 DMP Safety offices came to site to audit RGN1 testing operations. See DMP action tracker




3/05/2016 MA, JM, PA: Update on RGPF operations and heads-up on upcoming OSC and Drilling SMS submissions. Review of RGN1 well test audit. See DMP action tracker X:\HSEQ (CORPORATE)\1. EMPIRE HSEQ MS\10. Communications\1. Regulatory Meetings\DMP Meetings

Complete actions in action tracker


Tony Ruse & care taker

RGN1 C&T Tony Ruse Phone Calls 1/05/2016 to

31/08/2016

A number of phone calls exchanged between Tony Ruse, Ken Aitken and John Mastrocionque to keep him informed on status of future operations. Notified that planning and decision making were still underway.

Keep Tony informed of any future developments.


Tony Ruse & care taker

RGN1 C&T Tony Ruse & care taker Letter / Email 30/03/2016 Sent letter (email) for operational update and well test summary. None Ongoing / Satisfactory

Farm neighbour RGN1 C&T Arthur Dewar Phone Call Letter / Email

30/03/2016 Phone call to let them know letter is coming. Had a chat but no concerns raised. Email confirmed, and scan sent.

Confirm exact dates for flaring a couple of days before.


Judith Blenkinsop

RGN1 C&T Judith Blenkinsop Letter 30/03/2016 Sent letter (post) for operational update and well test summary. Recommend also dropping letter in person / visit.


Farm neighbour RGN1 C&T Gavin Drew Phone Call Letter / Email

30/03/2016 Phone call to let them know letter is coming. Email confirmed, and scan sent.

None Ongoing / Satisfactory

Phil Yukich RGN1 C&T Phil Yukich Phone Call Letter / Fax

30/03/2016 Phone call to let them know letter is coming. Fax number obtained, and copy sent. Phil re-iterated concern for his sheep and that he would probably be there on when we start flaring to confirm if the sheep are disturbed. He will be back in the Swan Valley on Friday and would appreciate if we dropped by to visit him at some stage next week.

Organise for a face to face a week before flaring start.


New tenant in Tony Ruse farmhouse

RGN1 C&T Jep (ph: 0428690806) KW visited the house

27/03/2016 KW visited the farmhouse to introduce Empire to the new tenant. He is very friendly and not really concerned about what we are doing. Tony has told him that there may be some noise during the testing operations.

Include him in distribution of the letter to all neighbours


DMIRS RGN1 PEB Submission & Letter 16/03/2016 Submission of EP BD for RGN1 completion and well test activity DMP acceptance of EP BD for RGN1 completion and well test activity received 21/03/2016

DMP to assess

Approval received

Landowner RGN1 Neighbour (Mc) Phone & Letter 24/02/2016 Empire contacted Neighbour (Mc) to advise of upcoming April 2016 RGN1 completion and testing operation. Neighbour confirmed there was no one living at the property that could be disturbed.

Provide letter

Letter sent





Status / Resolution

Empire to provide follow-up letter

Landowner RGN1 Neighbour (PY) Phone, Email, Phone & Letter

24/02/2016 Empire called neighbour (PY) to discuss changes in the company, advise of upcoming April 2016 RGN1 completion and testing operation. Empire enquired whether there were any issues associated with the drilling campaign. Neighbour raise concerns about sheep flock. Empire to call neighbour’ agricultural advisor to discuss sheep flock management measures then confirm management measures with neighbour. Empire to provide formal letter providing details of sheep flock management measures

Confirm sheep flock management measures with agricultural advisor

Sheep flock management measures developed and confirmed with neighbour

Provide letter

Complete

Landowner RGN1 Neighbour (G&S D) Phone & Letter 12/02/2016 Empire called neighbour (G&S D) to advise of upcoming April 2016 RGN1 completion and testing operation. Empire enquired whether there were any issues associated with the drilling campaign. Neighbour mentioned that there was some noise at times but no issues. Empire to provide written notification at least 2 weeks prior to activity commencement to confirm timing

Written notification required at least 2 weeks prior to activity commencement

Complete

Landowner RGN1 Neighbour (JB) Meeting & Letter 12/02/2016 Empire met with neighbour (JB) to advise of upcoming April 2016 RGN1 completion and testing operation. Empire explained that noise and visual amenity would not be an issue as per the Red Gilly West-1 program.

Formal letter required providing details discussed

Letter sent Complete

Landowner RGN1 Neighbour (AD) Phone & Letter 12/02/2016 Empire called neighbour (AD) to advise of upcoming April 2016 RGN1 completion and testing operation. Empire enquired whether there were any issues associated with the drilling campaign. Neighbour mentioned that there was some noise at times but no issues. He was concerned about the previous well test noise on Red Gully West-1 but was cognisant of the greater distance to RGN1 and appreciated the early consultation. Empire to provide written notification at least 2 weeks prior to activity commencement to confirm timing Noise monitoring at neighbour’s front gate required and test timing reviewed if noise is an issue

Written notification required at least 2 weeks prior to activity commencement

Complete

Noise monitoring required

Noise monitoring undertaken

DMP - Environment Regulator

RGN1 C&T Corrie Watts Phone Call 1/02/2016 Discussed upcoming completion and testing campaign and proposed approach to submit EP BD. Discussed noise management, updated chemical requirements, option for vertical flare and proposal to line/bund underneath flare area - No issues were raised.

Lodge EP BD document

Closed / Satisfactory



28/01/2016 JM, PA: Update on RGPF operations and review of drilling operations. DMP planning an audit of the completion and testing work.



Red Gully Farm owner (Lot 5448)

RGN1 C&T Tony Ruse Phone Call 14/01/2016 KW spoke to tony ruse: Follow-up with revised agreement /






Status / Resolution

Generally he is happy with things and is curious as to what happens next. I advised that we were reviewing our technical and commercial options and would advise by end Jan. He told me that he wanted the gate at the road kept shut now. I asked that if he has a padlock then we include our padlock in the links. He agreed and will check to see if our old combination lock is still there. He told me that he would have sheep in the laneway on route to RGN wellsite and that whilst it was ok to drive along the road it is essential that any gate found closed should be closed after we pass through – normal country rules where I come from. Secondly that we should advise all drivers to watch out for the sheep.

update letter.



Appendix A

Nomination of Operator



Appendix B

Empire Environment Policy



Appendix C

Empire Risk Matrix



Appendix D

Cardno Desktop Hydrogeological Study